Skip to main content

Full text of "Restart of the Pilgrim I Nuclear Powerplant : hearing before the Committee on Labor and Human Resources, United States Senate, One Hundredth Congress, second session ... January 7, 1988--Plymouth, MA"

See other formats


S.  R-RG.  100-598 

RESTART  OF  THE  PILGRIM  I 
NUCLEAR  POWERPLANT 


HEARING 

BEFORE  THE 

COMMITTEE  ON 

LABOR  AND  HUMAN  RESOURCES 

UNITED  STATES  SENATE 

ONE  HUNDREDTH  CONGRESS 
SECOND  SESSION 

ON 

EXAMINING  THE  PROPOSED  RESTART  OF  THE  PLYMOUTH,  MA,  NUCLE- 
AR POWERPLANT,  AND  THE  POTENTIAL  IMPLICATIONS  FOR  THE 
PUBLIC  HEALTH  AND  SAFETY  IN  THE  SURROUNDING  COMMUNITIES 


JANUARY  7,  1988— PLYMOUTH,  MA 


Printed  for  the  use  of  the  Committee  on  Labor  and  Human  Resources 


S.  Hrg.  100-598 

RESTART  OF  THE  PILGRIM  I 
'  NUCLEAR  POWERPLANT 


HEARING 

BEFORE  THE 

COMMITTEE  ON 

LABOK  AND  HUMAN  EESOUKCES 

UNITED  STATES  SENATE 

ONE  HUNDREDTH  CONGRESS 

SECOND  SESSION 

ON 

EXAMINING  THE  PROPOSED  RESTART  OF  THE  PLYMOUTH,  MA,  NUCLE- 
AR POWERPLANT,  AND  THE  POTENTIAL  IMPLICATIONS  FOR  THE 
PUBLIC  HEALTH  AND  SAFETY  IN  THE  SURROUNDING  COMMUNITIES 


JANUARY  7,  1988— PLYMOUTH,  MA 


Printed  for  the  use  of  the  Committee  on  Labor  and  Human  Resources 


U.S.   GOVERNMENT  PRINTING  OFFICE 
83-478  WASHINGTON   :  1988 

For  sale  by  the  Superintendent  of  Documents,  Congressional  Sales  Office 
U.S.  Government  Printing  Office,  Washington,  DC  20402 


COMMITTEE  ON  LABOR  AND  HUMAN  RESOURCES 

EDWARD  M.  KENNEDY,  Massachusetts,  Chairman 

CLAIBORNE  PELL,  Rhode  Island  ORRIN  G.  HATCH,  Utah 

HOWARD  M.  METZENBAUM,  Ohio  ROBERT  T.  STAFFORD,  Vermont 

SPARK  M.  MATSUNAGA,  Hawaii  DAN  QUAYLE,  Indiana 

CHRISTOPHER  J.  DODD,  Connecticut  STROM  THURMOND,  South  Carolina 

PAUL  SIMON,  Illinois  LOWELL  P.  WEICKER,  Jr.,  Connecticut 

TOM  HARKIN,  Iowa  THAD  COCHRAN,  Mississippi 

BROCK  ADAMS,  Washington  GORDON  J.  HUMPHREY,  New  Hampshire 
BARBARA  A.  MIKULSKI,  Maryland 

Thomas  M.  Roluns,  Staff  Director  and  Chief  Counsel 
Kevin  S.  McGuiness,  Minority  Staff  Director  and  Chief  Counsel 

(n) 


CONTENTS 


STATEMENTS 
Thursday,  January  7,  1988,  Plymouth,  MA 

Page 

Agnes,  Peter,  Assistant  Secretary  of  Public  Safety;  Sharon  Pollard,  Secretary 

of  State  of  Energy;  and  Deborah  Prothrow-Stith,  Health  Commissioner 434 

Prepared  statements  of: 

Mr.  Agnes 437 

Dr.  Prothrow-Stith 447 

Alexander,  Lawrence,  State  Representative;  Peter  Forman,  State  Representa- 
tive; David  Malaguti,  chairman  of  the  Pljmiouth  Board  of  Selectmen;  and 

Rachel  Shimshak,  Massachusetts  Public  Interest  Research  Group 97 

Prepared  statements  of: 

Mr.  Alexander 100 

Mr.  Forman 10*7 

Ms.  Shimshak 123 

Bosen,  Theodore,  Anti-Nuclear  Board  member,  prepared  statement 861 

Boston  Edison  Co.,  prepared  statement 780 

Cobb,  Dr.  Sidney,  prepared  statement  (with  attachments) 827 

Golden,  William,  State  Senator,  Norfolk,  Plymouth  District;  Grace  Healy, 
chairperson  of  Plymouth  Committee  on  Nuclear  Matters;  Mary  Ott,  co- 
chairperson  of  Citizens  Urging  Responsible  Energy;  Neil  Johnson,  chairper- 
son of  the  Duxbury  Citizens  Committee  on  Nuclear  Matters;  Ann  Waitkus- 
Amold,  chairperson  of  the  Disabled  Persons  Advisory  Group  on  Nuclear 
Evacuation  for  the  State  Office  on  Handicap  Affairs,  and  William  Abbott, 

president  of  the  Plymouth  County  Nuclear  Information  Committee,  Inc 3 

Prepared  statements  of: 

Mr.  Golden 4 

Mr.  Abbott 16 

Ms.  Waitkus-Arnold 25 

Mr.  Johnson 33 

Ms.  Ott  (with  attachments) 40 

Dr.  Healy  (with  attachments) 55 

Kerry,  Hon.  John  F.,  prepared  statement  (with  an  attachment) 458 

Kirby,  Hon.  Edward  P.,  State  Senator,  Second  Plymouth  District,  Common- 
wealth of  Massachusetts,  prepared  statement 855 

Krimm,  Richard,  Assistant  Associate  Director  of  FEMA;  Dr.  Thomas  Murley, 
Director  of  the  NCR's  Office  of  Nuclear  Reactor  Regulations;  William  Rus- 
sell, NCR's  Regional  Administrator,  Region  I;  and  Jack  Doland,  FEMA 

Region  1 531 

Prepared  statements  of: 

Mr.  Krimm  (with  an  attachment) 533 

Mr.  Murley 600 

Kugelmann,  Eileen,  director,  Mass  Safe  Energy  Alliance  (SEA):  Cape  Cod, 

prepared  statement 853 

Murphy,  Lt.  Gov.  Eveljm 322 

Prepared  statement 325 

Shannon,  Attorney  General  James 332 

Prepared  statement 335 

Studds,  Hon.  Gerry  E.,  prepared  statement 456 

Theriault,  Judy,  prepared  statement 854 

(HI) 


Articles,  publications,  etc.: 

The  Pilgrim  Generating  Facility  at  Plymouth,  Report  of  the  Joint  Special 
Committee  established  for  the  purpose  of  making  an  investigation  and      Page 
study,  excerpts  from,  July  1987 128 

MASSPRIG— Blueprint  for  Chaos  II:  Pilgrim  Disaster  Plans  Still  a  Disas- 
ter       162 

No  Exit— The  MASSPIRG  Survey  of  Pilgrim  Evacuation  Planning,  Sep- 
tember 1987 244 

Nuclear  Lemon — Rateplayer  Savings  from  Retiring  the  Pilgrim  Nuclear 
Powerplant,  November  1987 281 

Petition  of  Michael  S.  Dukakis,  Governor  and  James  S.  Shannon,  Attor- 
ney General  for  the  institution  of  proceeding  pursuant  to  10  C.F.R.  Sec. 
2.202  to  modify,  suspend,  or  revoke  the  operating  license  held  by  the 
Boston  Edison  Co.  for  the  Pilgrim  Nuclear  Station,  dated:  October  15, 
1987 341 

Review  of  the  status  of  the  Mark  I  BWR  Liner  Melt-Through  Issue,  by 
G.A.  Greene,  Brookhaven  National  Laboratory  Experimental  Modeling 
Group,  Upton,  NY 552 

The  Potential  Adverse  Health  Effects  of  the  Plymouth  Nuclear  Power 

Facility,  by  Belton  Burrows,  M.D.,  and  Donald  Muirheadm,  Jr.,  M.D 846 

Communications  to: 

Wyngaarden,  Dr.  James  B.,  Director,  National  Institutes  of  Hegdth,  from 
Senator  Edward  M.  Kennedy,  January  7,  1987 92 

Kennedy,  Hon.  Edward  M.,  U.S.  Senate,  from  James  B.  Wyngaarden, 
M.D.,  Director,  National  Institutes  of  Health,  January  28,  1987 94 

Zech,  Hon.  Lando,  Chedrman,  Nuclear  Regulatory  Commission,  from 
David  P.  Malaguiti,  chairman,  Board  of  Selectmen,  September  2,  1987  ...      116 

Hurley,  Thomas  S.,  Director,  Office  of  Nuclear  Reactor  Regulation,  Wash- 
ington, DC,  from  David  F.  Malaguti,  chairman.  Board  of  Selectmen, 

November  6,  1987 118 

Questions  and  answers: 

Response  of  Mr.  Krimm  to  questions  submitted  by  Senator  Kennedy 777 

Response  of  Mr.  Murley  to  questions  submitted  by  Senator  Kennedy 617 


RESTART  OF  THE  PILGRIM  I  NUCLEAR  POWER- 
PLANT 


THURSDAY,  JANUARY  7,  1988 

U.S.  Senate, 
Committee  on  Labor  and  Human  Resources, 

Plymouth,  MA. 

The  committee  met  at  7  p.m.,  at  the  Carver  Regional  High 
School,  Plymouth,  MA,  Senator  Edward  M.  Kennedy  (chairman  of 
the  committee)  presiding. 

OPENING  STATEMENT  OF  SENATOR  KENNEDY 

The  Chairman.  We'll  come  to  order.  We  have  a  very  full  pro- 
gram this  evening  and  this  is  an  extremely  important  hearing. 
We're  going  to  insist  on  order.  We  very  much  appreciate  all  the 
courtesies  that  have  been  provided  by  the  townspeople  here  in 
Plymouth.  We  want  to  thank  Mr.  Simon,  the  superintendent  of 
schools,  for  making  the  facility  possible. 

As  I  mentioned,  we  have  a  full  agenda,  a  number  of  panels.  We 
want  to  make  sure  that  the  views  of  all  of  our  witnesses  are  given 
adequate  consideration,  so  we're  going  to  insist  that  the  hearing 
move  along.  In  a  situation  like  this,  we  are  always  caught  in  a 
time-bind  between  giving  people  an  opportunity  to  speak  and  re- 
ducing the  amount  of  time  that  people  have,  but  that  is  the  nature 
of  many  of  these  hearings,  particularly  those  hearings  that  we 
have  out  in  the  field. 

We  will  ask  all  of  the  witnesses  on  the  panels  to  limit  their  state- 
ments to  three  minutes.  If  they  have  additional  comments,  they 
can  make  those  statements  a  part  of  the  record. 

I  would  expect  in  a  hearing  like  this  that  anyone  who  is  going  to 
appear  before  this  committee  ought  to  be  able  to  summarize  their 
views  since  we  are  looking  at  expert  testimony. 

We  will  try  and  conclude  this  hearing  around  9:30  or  quarter  of 
10.  If  it  looks  like  we're  going  later  then  that,  we'll  take  a  brief 
break  part  way  into  the  hearing,  in  a  couple  of  hours. 

I'll  make  a  brief  opening  statement,  and  then  we'll  move  on  to 
the  first  panel  of  witnesses. 

We're  going  to  insist  that  all  of  our  witnesses  be  sworn  in  during 
the  course  of  these  hearings.  We  are  going  to  insist  on  order  and 
we're  going  to  desist  from  any  exclamations  of  approval  or  disap- 
proval. We're  going  to  maintain  the  decorum  of  a  committee  of  the 
United  States  Senate. 

The  Committee  on  Labor  and  Human  Resources  is  here  to  look 
into  the  proposed  restart  of  the  Plymouth  Nuclear  Power  Plant, 

(1) 


and  its  potential  implications  for  the  public  health  and  safety  in 
the  surrounding  communities.  This  committee  has  had  a  long  in- 
volvement in  oversight  of  nuclear  powerplant  safety  and  its  effects 
on  public  health.  In  1979,  the  committee  held  hearings  on  the  acci- 
dent at  Three  Mile  Island,  and  a  year  ago,  we  investigated  the  acci- 
dent at  Chernobyl  in  the  Soviet  Union. 

Since  the  dawn  of  nuclear  power,  we  have  learned  a  great  deal 
about  its  potential — and  about  its  awesome  possibilities  for  destruc- 
tion. We  know  more  today  about  the  health  effects  of  radiation  ex- 
posure, but  many  unanswered  questions  remain.  And  there  is  one 
fact  of  which  we  are  certain,  radiation  if  unleashed  can  cause  un- 
paralleled injury  and  devastation.  The  world  learned  that  lesson 
again  from  the  tragedy  at  Chernobyl  where  31  people  lost  their 
lives  and  thousands  more  will  die  of  leukemia  and  other  radiation 
related  diseases. 

We  know  that  nuclear  plant  accidents  not  only  can  happen,  but 
do  happen.  In  fact,  the  Nuclear  Regulatory  Commission  estimates 
that  in  the  next  20  years,  there  is  a  substantial  chance  for  a  core 
meltdown  in  a  U.S.  powerplant. 

In  view  of  these  serious  implications,  the  NRC  should  be  evaluat- 
ing more  effective  ways  to  improve  public  safety.  Regrettably,  the 
opposite  has  been  true.  In  recent  years,  the  Commission  has  weak- 
ened its  efforts  to  protect  the  public.  And  the  experience  of  Plym- 
outh is  a  case  in  point. 

Plymouth's  history  is  replete  with  cases  of  mismanagement, 
equipment  failure  and  regulatory  violations.  In  May  1986,  NRC  of- 
ficials identified  it  as  one  of  the  least  safe  plants  in  the  country.  It 
has  been  involved  in  a  number  of  enforcement  actions,  and  in  Jan- 
uary 1982,  it  was  subjected  to  one  of  the  largest  NRC  tines  in  histo- 
ry, totaling  $550,000. 

Plymouth  has  also  received  excessive  "minimum  satisfactory" 
ratings  by  the  NRC  in  its  periodic  assessment  reports.  The  plant 
relies  on  a  containment  structure  that  many  experts  agree  is  likely 
to  rupture  in  the  event  of  high  pressure  buildup. 

Finally,  and  perhaps  more  important,  both  the  Commonwealth  of 
Massachusetts  and  the  Federal  Emergency  Management  Agency 
have  concluded  that  residents  living  near  the  plant  do  not  have  an 
adequate  evacuation  plan  in  the  event  of  a  radiation  emergency. 
Yet  despite  these  serious  ongoing  problems,  the  Commission  is  con- 
tinuing with  the  process  for  restarting  the  plant. 

Residents  and  State  officials  have  repeatedly  called  on  the 
Agency  for  meaningful  participation  in  the  restart  decisions.  Their 
petitions  have  fallen  on  deaf  ears.  The  NRC  has  consistently  reject- 
ed requests  to  hold  a  hearing.  To  some  extent  this  hearing  is  in- 
tended to  fill  that  gap. 

Our  concerns  are  not  limited  to  people  residing  within  the  10 
mile  emergency  planning  zone,  but  for  residents  of  Cape  Cod  and 
in  the  South  Shore  area  as  a  whole.  Residents  fear  that  they  will 
not  be  safely  evacuated  in  the  case  of  a  nuclear  accident,  and  their 
fear  is  compounded  because  the  plant's  record  is  unsatisfactory. 

Through  this  hearing,  the  committee  will  obtain  a  better  under- 
standing of  how  the  Commission  makes  its  restart  decision  and 
how  it  evaluates  recommendations  for  the  public,  from  the  State 
and  from  FEMA.  I  look  forward  to  hearing  from  the  witnesses. 


Our  first  panel  of  witnesses  this  evening  is  comprised  of  resi- 
dents of  this  area,  Plymouth  and  Duxbury,  which  could  be  most  di- 
rectly affected  by  a  restart  of  the  Pilgrim  plant.  They  have  done  a 
tremendous  amount  of  work  on  the  subject,  and  they  are  the  most 
vivid  proof  of  the  democratic  process  in  action.  So  I  welcome  them 
here  tonight.  I  would  like  them  to  come  to  the  witness  table  and 
we'll  all  hear  their  presentations. 

They  will  be  introduced  to  us  by  State  Senator  William  Golden, 
who  will  also  be  testifying  before  us  later  this  evening. 

STATEMENTS  OF  WILLIAM  GOLDEN,  STATE  SENATOR,  NORFOLK, 
PLYMOUTH  DISTRICT;  GRACE  HEALY,  CHAIRPERSON  OF  PLYM- 
OUTH COMMITTEE  ON  NUCLEAR  MATTERS;  MARY  OTT,  CO- 
CHAIRPERSON  OF  CITIZENS  URGING  RESPONSIBLE  ENERGY; 
NEIL  JOHNSON,  CHAIRPERSON  OF  THE  DUXBURY  CITIZENS 
COMMITTEE  ON  NUCLEAR  MATTERS;  ANN  WAITKUS-ARNOLD, 
CHAIRPERSON  OF  THE  DISABLED  PERSONS  ADVISORY  GROUP 
ON  NUCLEAR  EVACUATION  FOR  THE  STATE  OFFICE  ON  HANDI- 
CAP AFFAIRS,  AND  WILLIAM  ABBOTT,  PRESIDENT  OF  THE 
PLYMOUTH  COUNTY  NUCLEAR  INFORMATION  COMMITTEE, 
INC. 

Mr.  Golden.  Good  evening,  Mr.  Chairman.  For  the  record,  my 
name  is  State  Senator  William  Golden  from  the  Norfolk,  Plymouth 
District. 

It  is  my  pleasure  tonight  to  welcome  you  and  to  thank  you  for 
beginning  tonight  a  process  which  the  Nuclear  Regulatory  Commis- 
sion of  the  United  States  has  denied  the  people  of  America  and  the 
citizens  of  America's  hometown,  Plymouth,  and  that  is  the  opportu- 
nity to  participate  in  the  process  of  determining  the  future  of  the 
nuclear  power  plant  here  in  Plymouth. 

The  witnesses  on  this  panel  before  you  this  evening,  Mr.  Chair- 
man, will  be  Grace  Healy,  the  chairperson  of  Plymouth  Committee 
on  Nuclear  Matters;  Mary  Ott,  cochairperson  of  Citizens  Urging 
Responsible  Energy;  Neil  Johnson,  chairperson  of  the  Duxbury 
Citizens  Committee  on  Nuclear  Matters;  Ann  Waitkus-Arnold, 
chairperson  of  the  Disabled  Persons  Advisory  Group  on  Nuclear 
Evacuations  for  the  State  Office  on  Handicap  Affairs,  and  William 
Abbott,  president  of  the  Plymouth  County  Nuclear  Information 
Committee,  Inc. 

[The  prepared  statement  of  Mr.  Golden  follows:] 


TESTIMGtJY  OF  MASSACHUSETTS  STATE  SENATOR  WILLIAM  B.  GOLDEN 
BEFORE  THE  SENATE  COMMITTEE  ON  LABOR  AND  HUMAN  RESOURCES, 
JANUARY  6,  1988. 

Mr.  Chairman, 

I  want  to  thank  you  and  the  members  of  this  committee  for 
the  opportunity  to  testify  before  you  this  evening.   I  believe 
that  the  Piglrim  Nuclear  Power  Station  should  be  closed  for 
reasons  of  safety,  reliability  and  economics.   There  is 
overwhelming  evidence  that  it  is  one  of  the  worst-managed 
nuclear  plants  in  the  country.   Its  containment  vessel  has  been 
proven  to  be  defective.   No  emergency  plans  exist  to  adequately 
protect  the  public  in  the  event  of  a  serious  accident  at  the 
plant.   Evidence  also  has  been  mounting  of  serious  security  and 
radiological  control  problems  at  the  plant  and  a  recent  study 
has  demonstrated  that  it  would  be  less  expensive  to  shut  the 
plant  down  than  to  allow  it  start  up  again. 

Yet,  no  level  of  government  has  acted  decisively  to  shut 
this  plant  down.   Under  the  Atomic  Energy  Act,  states  have 


almost  no  power  regarding  the  safety  of  nuclear  power  plants. 
Federal  authority  -  which  is  embodied  in  the  Nuclear  Regulatory 
Commission  -  has  a  virtual  monopoly  regarding  the  operation  of 
nuclear  plants.   Unfortunately,  the  Nuclear  Regulatory 
Commission  has  failed  to  distinguish  between  plants  that  are 
safe  and  those  that  are  not.   Rather  than  providing  a  fair  and 
open  forum  for  resolution  o"f  nuclear  safety  concerns,  as  well 


Page  2 

TESTIMONY 

as  a  mechanism  for  closing  unsafe  plants,  the  NRC  has  chosen  to 
be  an  advocate  for  the  nuclear  industry.   Despite  all  of  the 
well-documented  problems  at  Pilgrim,  the  NRC  has  chosen  to  keep 
the  plant  licensed. 

In  July  of  1986  I  filed  a  petition  with  the  NRC 
requesting  a  formal  hearing  on  the  suspension  or  revocation  of 
Pilgrim's  license  to  operate.   Both  the  governor  and  the 
attorney  general  have  since  filed  similar  show-cause  petitions 
with  the  NRC  requesting  hearings  on  the  Pilgrim  license.   The 
NRC's  failure  to  consider  fully  and  fairly  these  petitions  has 
convinced  us  that  we  cannot  rely  on  the  NRC  to  protect  the 
public  from  the  dangers  presented  by  the  Pilgrim  nuclear  power 
plant . 

We  urgently  and  respectfully  request  that  you  join  our 
efforts  by  using  the  power  of  this  committee  to  demand  that  the 
NRC  hold  formal  hearings  so  that  Boston  Edison  may  demonstrate 
why  It  should  be  allowed  to  operate  a  plant  that  is  unsafe, 
unrealiable  and  uneconomical. 

A  year  and  a  half  ago,  I  testified  at  length  before  the 
Congressional  Sub-Committee  on  Energy,  Conservation  and  Power 
in  Washington,  D.C.,  on  the  problems  at  Pilgrim. 
Unfortunately,  very  little  has  changed  since  that  hearing,  and 
the  problems  that  I  discussed  in  that  testimony  have  not  been 
resolved.  Accordingly,  I  would  like  to  submit  that  testimony 
again  to  your  committee.   A  copy  of  it  is  attached. 


/ 


6 

T«.8timonv  of  Maaaachuaetta  State  Senator  Willlaa  fl.  Golden  befoyi* 
the  Conaresaional  Sub-Comaittee  on  Energy.  Conaervatlon  and 
Power.  July  16.  1986, 

Mr.  Chairauin: 

I  vajit   to  thank  you  ajid  the  membera  of  the  conunlttee  for 
giving  me  the  opportunity  to  appear  before  you  today.   Shortly 
alter  World  Nar  II.  the  federal  government  Initiated  a  bold 
national  policy  to  develop  the  peaceful  use  of  nuclear  energy. 
Today,  many  aspects  of  this  policy  have  failed.   These  failures 
imperil  the  health,  safety  and  welfare  of  milliona  of  Americana 
and  steund  in  the  way  ot  the  development  of  a  safe  amd  secure 
energy  luture.   it  13  critical  that  we  appreciate  what  these 
policy  failures  have  meant. 

The  nuclear  industry  has  not  achieved  uniform  standards  of 
excellence.   :iome  plants  have  state-of-the-art  technology.   Some 
are  well -managed.   Some  are  appropriately  located  in  areas  away 
from  population  centers.   Some  are  etficient,  coat-effective 
producers  of  electricity.  A  few — those  run  by  the  military- -have 
adequate  security. 

However,  many  others  were  poorly  designed  and  now  have 
outdated  equipment.  They  are  located  in  areas  that  are  densely 
populated  or  are  vulnerable  because  of  their  geography.  Some 
plants  are  poorly  managed.  Some  no  longer  make  economic  sense. 
Nearly  all  civiliam  reactors  have  inadequate  protection  from  new 
and  more  sophisticated  security  threats. 

The  federal  government,  which  has  the  central  responsibility 


lor  nuclear  safety,  has  tailed  to  understand  local  conditions  and 
concerns.   It  has  not  made  suilicient  distinction  between  good 
and  bad  nuclear  plants. 

Boston  Edison  s  Pilgrim  Nuclear  Power  Station--located  in 
America' s  home  town,  Plymouth,  Massachusetts--ha3  come  to 
symbolize  the  failure  of  this  policy.   The  problems  of  this  plant 
fall  in  five  broad  categories:  management,  technology,  emergency 
planning,  security  and  economics. 

Pilgrim  has  long  suffered  from  poor  management.   In  1982, 
the  Nuclear  Regulatory  Commission  levied  what  was  then  the 
largest  civil  penalty  in  the  agency's  history  against  Boston 
Edison  for  management  and  safety  problems.   The  NRC's  SALP 
reports,  or  overall  performance  reviews,  for  1981,  1982  and  1985 
gave  Boston  Edison  the  lowest  possible  rating  for  plcunt 
operations.   The  most  recent  ;5ALP  report,  issued  this  February, 
cited  the  company  ror  poor  starting,  supervision,  procedures  and 
self -assessment.   A  special  NRC  inspection  report  issued  on  April 
2,  again  pointed  out  stalling  and  organizational  deficiencies. 
In  May,  the  NRC  commissioners  told  this  committee  that  Pilgrim  is 
one  of  the  worst-run  and  least-safe  plants  in  the  country.   In 
June,  the  Massachusetts  Department  of  Public  Utilities  issued  a 
sweeping  criticism  of  Boston  Edison' s  overall  management, 
concluding  that  the  company  had  all  but  abdicated  its 
responsibility  for  planning. 

These  reports  and  disclosures  have  destroyed  public 
confidence  in  Boston  Edison  s  aUility  to  manage  Pilgrim  safely. 
They  are  sufficient  cause  for  the  NRC  to  hold  public  hearings  on 


8 


whether  this  utility  should  be  allowed  to  continue  to  run  the 
plant.   The  NRC  has  refused  to  take  this  step,  and  because  or 
this  refusal,  the  public  is  rapidly  losing  confidence  in  the 
NRCs  ability  to  regulate  Pilgrim. 

1  urge  this  committee  to  use  its  influence  to  persuade  the 
NRC  to  hold  hearings  on  the  possible  suspension,  revocation  or 
transfer  of  Boston  Edison  s  license  to  operate  Pilgrim. 

The  adequacy  of  Pilgrim  s  containment  structure  is  another 
matter  of  serious  concern.  Pilgrim  is  a  19603  model  General 
Electric  boiling  water  reactor  with  a  Marie  1  containment  vessel. 
The  NRCs  chief  safety  official,  Harold  Denton,  recently  stated 
that  there  is  a  90  percent  probaiJillty  of  failure  of  a  Mark  I 
vessel  in  the  event  of  a  core  meltdown.  This  level  of  risk  is 
intolerable.   The  NRC  should  demand  that  Pilgrim's  containment  be 
upgraded  to  the  highest  standards  the  industry  can  provide. 

The  NRC  can  no  longer  persist  in  ignoring  important  design 
distinctions  among  nuclear  plants.   It  is  time  to  determine 
whether  it  is  more  economical  to  upgrade  the  Mark  I  system  or  to 
close  plants  with  Mark  I  containment  permanently. 

No  issue  so  plainly  illustrates  the  failure  ot  national 
nuclear  policy  as  emergency  preparedness.   ITie  public  might  be 
more  inclined  to  accept  the  pronouncements  or  the  experts  on  the 
highly  technical  issues  surrounding  nuclear  power  if  the 
emergency  plans  for  nuclear  plants  were  not  so  patently 
inadequate. 

The  10-mile  emergency  preparedness  zone,  which  the  NRC 
requires  of  all  nuclear  facilities,  may  make  sense  tor  a  plant 


located  m  the  middle  oi  a  western  desert.   But  it  is  clearly 
inappropriate  for  densely  populated  urban  and  suburban  areas  of 
the  Northeast. 

A  serious  accident  at  Pilgrim  would  have  effects  far  beyond 
the  10-mile  zone.   Flans  should  be  developed  to  deal  with  an 
emergency  at  Pilgrim   that  would  affect  Boston,  which  is  40  miles 
away,  or  Cape  Cod,  which  is  only  12  miles  from  the  plant. 

Boston  Edison,  the  NRC,  and  the  Federal  Emergency  Management 
Agency  have  assigned  a  low  priority  to  emergency  planning.   The 
Pilgrim  plan  has  never  received  formal  approval  from  FEMA  or  the 
NRC.      FEMA  did  not  even  receive  a  copy  of  the  most  recent  Pilgrim 
plan  until  ten  months  after  it  was  prepared. 

Neither  the  utility  nor  the  federal  government  has  dealt 
with  the  cost  or  adequate  emergency  planning.   In  an  actual 
emergency,  the  crucial  links  in  tne  chain  or  command  are  unpaid, 
minimally  trained  local  civil  defense  directors.  For  any  plan  to 
work,  professional  civil  defense  departments  with  adequate  staffs 
and  equipment  must  be  in  place. 

In  this  age  of  global  terrorism,  political  extremism  and 
individual  fanaticism,  it  is  imperative  that  security  be  upgraded 
at  Pilgrim  and  all  other  nuclear  plants.   Official  NRC 
regulations  call  for  strict  security  at  nuclear  plants.   However, 
this  official  policy  has  not  been  effectively  implemented  by  the 
nuclear  industry  or  the  NRC. 

In  an  attempt  to  lull  the  public  into  a  comfortable  feeling 
about  nuclear  power,  the  Atomic  Industrial  Forum- -a  nuclear 
industry  organization- -suggested  last  week  that  nuclear  power 


10 


plants  are  ideal  summer  tourist  attractions.  ITiis  attitude  is 
irresponsible  and  dangerous.   :3ecurlty  interests  require  that  the 
public  be  kept  as  rar  away  as  possible  from  nuclear  plants. 

The  NRC  has  tailed  to  realize  that  the  eif ectiveness  of  its 
elcLborate  security  regulations  is  no  better  than  the  individuals 
who  carry  them  out.   At  Pilgrim  this  taslc  falls  to  individuals 
who  are  recruited  through  classified  ads  in  the  local  weekly 
newspaper  stating,  "We  are  looking  for  those  individuals  with  a 
career  as  a  nuclear  security  officer  in  mind  and  would  like  to 
earn  $11,000  to  $18,000. .. You  must  be  at  least  19  years  old  and 
must  bring  with  you  copies  oi  birth  certificate,  drivers  license, 
high  school  diploma  or  G.E.D.  certificate."   Security  at  nuclear 
plants  demands  higher  standards. 

At  Pilgrim,  security  problems  are  compounded  by  reports  or 
alcohol  and  drug  abuse,  horseplay  m  sensitive  parts  of  the  plant 
and  continuing  labor -management  strife. 

This  committee  should  seriously  consider  having  the  United 
;itates  military  or  the  Department  of  Defense  police  provide 
direct  security  for  Pilgrim  and  all  other  nuclear  plants. 
Nuclear  facilities  are  not  tourist  attractions.   They  are 
sensitive  installations  which  in  the  wrong  hands  could  expose 
civillem  populations  to  catastrophic  dsmgers. 

Finally,  national  nuclear  policy  has  failed  because  the 
federal  government  has  lost  sight  of  the  policy's  prime 
objective — cheap  energy.   A  chairman  of  the  Atomic  Energy 
Commission  once  stated  that  nuclear  power  would  give  us 
electricity  "too  cheap  to  meter."   This  clearly  has  proven  false. 


11 


Today,  we  need  to  re-examine  ail  of  the  old  assumptions 
surrounding  the  economics  ol  nuclear  power. 

A  cost-benefit  analysis  of  Pilgrim  has  not  been  conducted 
since  the  plant  went  on  line  15  years  ago.  Pilgrim  and  other 
existing  plants  are  becoming  increasingly  expensive  to  run,  as 
the  costs  or  maintenance  and  safety  improvements  escalate.   The 
public  IS  demanding  better  security,  management  and  safety  at 
nuclear  plants.   These  measures  will  cost  money.   The  economics 
of  all  nuclear  plants  should  be  subjected  to  thorough  reviews. 

These  reviews  also  should  talce  into  account  items  that  are 
undervalued  on  company  balance  sheets  or  may  not  show  up  at  all. 
The  public  has  subsidized  nuclear  power  by  limiting  utility 
liability  for  accidents  through  the  Price  Anderson  Act.  Civil 
defense  planning  and  government  regulation  are  other  costs  to  the 
public  of  nuclear  power.   The  future  costs  of  decommissioning  and 
waste  disposal  are  still  unlcnown. 

_I  urge  this  committee  to  press  for  the  suspension  of 
Pilgrim  3  license  until  the  following  actions  are  tatcen; 

1)  The  NRC  holds  public  hearings  on  whether  Boston  Edison  is 
qualiiied  to  manage  the  plant. 

2)  The  reconstruction  or  replacement  of  the  existing 
containment  vessel  so  that  Pilgrim  has  a  state-of-the-art 
containment  system. 

3)  The  creation  of  a  4u-mile  emergency  planning  zone  and  the 
development  of  a  new  civil  defense  program,  which  would  be  funded 
by  Boston  Edison  and  would  be  capable  of  responding  to  a  serious 
accident  at  Pilgrim. 


12 

4)  Ttie  lOfmatlOn  of  a  military  or  Deiense  Department  police 
security  iorce  I'or  Pilgrim  and  all  other  nuclear  racilities. 

5)  The  completion  ot  an  economic  C03t/benetit  analysis  ot 
Pilgrim. 

Three  Mile  island  and  Chernobyl  have  changed  forever  the  way 
Americans  think  about  nuclear  power.   The  test  of  our  national 
nuclear  energy  policy  no  longer  lies  in  a  comlortable  consensus 
between  the  utility  industry  and  the  NRC.   To  survive,  nuclear 
power  must  prove  itself  not  just  in  the  nation' s  capital  but  in 
Plymouth,  Massachusetts,  and  other  home  towns  throughout  America. 
It  is  time  for  the  rederal  government  to  stop  listening  only  to 
experts  and  technocrats  and  to  start  listening  to  the  American 
people.   No  policy  will  succeed  until  public  coniidence  is 
restored  in  the  technology  and  in  the  ability  of  governemnt  to 
manage  it  in  the  public  interest. 


13 

The  Chairman.  Well,  thank  you  very  much,  Senator  Golden.  We 
will  ask  all  of  you  if  you  would  be  kind  enough  to  stand. 

[Witnesses  sworn.] 

The  Chairman.  We'll  start  with  Mr.  Abbott. 

Mr.  Abbott.  Mr.  Chairman,  thank  you  for  the  opportunity  to  tes- 
tify before  your  committee.  You  have  asked  here  tonight  what  will 
be  the  impact  upon  the  health  and  safety  of  the  communities  sur- 
rounding the  Pilgrim  I  plant  should  it  be  allowed  to  start  up  in  the 
next  few  months. 

Others  here  tonight  will  address  the  issue  of  protection  against  a 
catastrophic  accident  and  emergency  planning.  I  would  like  to 
focus  my  brief  comments  and  recommendations  on  the  subject  of 
radiation  emissions  for  Pilgrim  I  and  their  control  and  their  moni- 
toring, or  as  is  usually  the  case,  the  lack  thereof  by  the  NRC. 

Over  a  year  ago,  I  testified  before  two  Massachusetts  legislative 
committees  advocating  the  funding  of  an  effective  monitoring 
system  by  the  State  of  Massachusetts  to  do  what  the  NRC  does  not 
perform.  Legislation  was  introduced,  but  it  died  a  few  days  ago  in 
the  final  hours  of  the  1987  legislative  session;  thus  we  must  still 
rely  on  the  NRC  to  police  the  operations  of  Pilgrim  I;  a  reliance, 
which  based  on  past  experience,  certainly  gives  me  and  the  resi- 
dents of  this  area  little  comfort. 

Pilgrim  I  has  had  a  history  of  continued  unplanned  radiation  re- 
leases, which  are  among  the  highest  in  the  nation.  Again  and 
again,  we  see  reports  of  radiation  releases  in  the  files;  we  must  dili- 
gently dig  through  unpublicized  NRC  reports  to  see  that  there  is 
this  recurrent  public  health  menace. 

Now,  Senator,  given  the  reports  of  substantially  higher  than  av- 
erage incidents  of  cancer  in  Plymouth  and  towns  downwind  of  the 
plant,  the  do-nothing  approach  by  the  State  of  Massachusetts  and 
by  the  NRC  can  no  longer  be  tolerated.  To  date,  our  efforts  have 
been  singularly  unsuccessful  in  getting  the  NRC  to  do  anything 
about  this.  They  have  failed  miserably  over  the  years,  both  in  dis- 
charging their  public  protection  function,  and  equally  as  impor- 
tant, in  giving  the  public  any  comforting  perception  that  it  is  ful- 
filling this  function. 

Operating  from  a  distance,  whether  it  be  King  of  Prussia,  PA,  or 
Washington,  the  NRC's  typical  involvement  is  to  become  activated 
after  receiving  a  report  from  Edison;  dispatch  a  team  to  the  site; 
listen  to  Edison's  explanation,  and  then  generally  endorse  and 
ratify  Edison's  report  with  the  usual  conclusion,  without  any  fur- 
ther investigation,  that  the  public  health  was  not,  in  fact,  impacted 
by  the  incident. 

Massachusetts,  likewise,  has  effectively  failed  to  monitor  the 
plant.  We,  through  a  Federal  court  suit  years  ago,  got  the  Depart- 
ment of  Public  Health  to  install  dosimeters  in  Plymouth  and  sur- 
rounding towns  to  monitor  the  release  of  radiation. 

Unfortunately,  the  carrying  out  of  this  function  has  been  proven 
nearly  worthless  since  the  devices  are  only  read  quarterly;  results 
are  hidden  from  public  view,  and  even  worse,  Mr.  Chairman,  no  at- 
tempt is  made  to  correlate  the  reading  of  these  devices  with  known 
accidents  at  the  plant  which  could  lead  to  off-site  releases,  despite 
Edison's  predictable,  self-serving  statements  that  all  releases  are 
contained  within  the  site  perimeter. 


14 

Let  me  illustrate  this  fundamental  failure  with  one  example  to 
show  you  that  the  responsible  authorities  are  not  protecting  the 
citizens  of  the  South  Shore.  We  researched  this  ourselves. 

In  June  1982,  Edison  sent  a  detailed  report  to  the  NRC  regional 
office  explaining  that  highly  radioactive  resin  beads  and  particu- 
late matter,  which  had  accumulated  over  an  extended  period  of 
time,  were  found  to  have  been  accidently  injected  into  the  ventila- 
tion system  and  from  there  to  the  outside  of  the  building.  This  ma- 
terial was  discovered  on  the  roofs  of  several  of  the  buildings  and  on 
the  grounds  of  the  Pilgrim  I  plant  site. 

The  Region  I  NRC  office  dispatched  a  team  to  the  site  and  found 
that  this  material  had  been  probably  released  through  the  vent 
duct  which  exhausts  to  the  atmosphere  at  an  elevation  of  about  100 
feet.  Ten  cubic  feet  of  this  highly  radioactive  resin  was  found  in 
the  standby  gas  treatment  system  inlet  plenum.  This  is  the  source 
of  releases  of  radioactive  materials  to  the  atmosphere. 

Now,  despite  the  very  serious  potential  of  this  accident  for  off- 
site  contamination  and  the  carrying  away  of  radioactive  dust  by 
the  winds,  no  effort  was  made  to  read  the  off-site  TLDS — there  are 
three  separate  sets  of  these  maintained  by  the  NRC,  Boston  Edison 
and  the  State  of  Massachusetts — no  efforts  were  made  to  correlate 
those  readings  with  this  observed  accident.  Nobody  bothered  to 
read  them  to  see  if  Edison's  statement  made  at  the  time — that  no 
radiation  escaped  off-site — was,  in  fact,  true. 

Now,  this  failure  was  probably  due  to  the  fact  that  the  readings 
did  not  become  available — they  are  only  read  quarterly — until  sev- 
eral weeks  after  the  particular  release. 

We  did  check  the  readings,  and  the  results  were  highly  signifi- 
cant. For  instance,  in  the  summer  of  1982,  all  TLD  locations  as 
measured  by  Edison,  the  NRC  and  the  State  showed  a  large  rise 
and  then  declined  by  the  same  percentage,  indicating  a  consistent 
pattern.  Likewise,  the  dose-rate  decreased  with  distance  away  from 
the  plant  as  one  would  expect  from  a  point  source.  The  zone  closest 
to  the  plant  showing  the  largest  dose-rate. 

The  Chairman.  What  do  those  kinds  of  increases  mean  in  practi- 
cal terms,  in  terms  of  the  health  hazard  for  the  population? 

Mr.  Abbott.  Senator,  they  are  substantially  in  excess  of  back- 
ground radiation,  and  I  think  that  anytime  you  add  to  the  back- 
ground radiation  more  radiation  from  the  Pilgrim  nuclear  plant, 
you  are  adding  to  the  health  hazard  of  the  people  of  the  area. 

We  have  asked  the  State  of  Massachusetts  to  hold  hearings  to  set 
new  levels  of  radiation  standards,  emission  standards.  This  is  one 
of  the  problems  we  have  with  the  NRC,  that  the  standards  that 
they  have  are  not  consistent  with  current  scientific  evidence.  But 
the  key  here  is  that  although  the  statement  was  made  that  nothing 
escaped,  clearly  radiation  did  escape.  Out  as  far  as  20  miles  toward 
the  northwest,  all  locations  showed  an  increase  of  radiation.  The 
existing  background  dose-rates  were  nearly  tripled  in  the  third 
quarter  of  1982. 

About  a  year  ago,  I  discussed  this  at  a  meeting  with  NRC  at  a 
public  forum.  They  told  me  that  they  had  not  read  the — the  gentle- 
man that  was  there  was  on  the  NRC  team  that  inspected  the  plant 
after  that  accident — had  not  read  the  TLD  data.  He  said  some  four 
years  after  the  incident  he  thought  the  TLD  data  was  "worth 


15 

checking."  The  State  Department  of  Public  Health  did  not  do  much 
better. 

The  Chairman.  I'll  give  you  another  minute. 

Mr.  Abbott.  The  remedy  to  this  failure  is  starkly  obvious.  Either 
the  NRC  or  the  State  or  both  should  gear  up  with  the  necessary 
manpower  and  equipment  to  monitor  the  day-to-day  operations  at 
Pilgrim  I,  including  all  planned  and  unplanned  releases  of  radi- 
ation on  a  regular,  continuous  basis,  not  this  haphazard  hit-or-miss 
system  that  we  have  now.  Monitoring  equipment  should  be  read  on 
a  real-time,  continuous  basis  up  to  at  least  20  miles  from  the  plant, 
and  the  results  made  public  so  we  don't  have  to  search  for  them. 
Until  that  is  in  place.  Senator,  I  say  the  plant  should  not  be  al- 
lowed to  re-open. 

The  people  of  the  South  Shore  deserve  to  know  what  they  are 
being  exposed  to.  It  is  of  fundamental  importance  to  our  mental 
well-being  and  physical  health  that  this  system  be  in  place.  We  ask 
the  support  of  your  committee  to  insure  that  the  NRC  not  give  its 
approval  to  Pilgrim  restart,  unless  and  until  an  effective  real-time, 
continuous  radiation  monitoring  system  has  been  fully  implement- 
ed. Thank  you. 

[The  prepared  statement  of  Mr.  Abbott  follows:] 


16 


statement  of  William  S.  Abbott 

President,  Plymouth  County  Nuclear  Information  Committee, 

before  Senate  Committee  on  Labor  and  Human  Resources, 

on  January  7,  1988 

Thank  you  for  the  opportunity  to  testify  before  your  Committee, 
You  have  asked  here  today  what  would  be  the  impact  upon  the  health 
and  safety  of  the  surrounding  communities  from  the  operation  of 
Pilgrim  I  should  it  be  allowed  to  start  up  by  the  NRC  in  the  next 
few  months.   Others  here  today  have  addressed  or  will  address  the 
issues  of  protection  against  a  catastrophic  accident  and  emergency 
planning.   I  would  like  to  focus  my  comments  and  recommendations 
on  the  subject  of  radiation  emissions  from  Pilgrim  I  and  their 
control  and  their  monitoring  (or  as  is  more  usually  the  case,  the 
lack  thereof)  by  the  NRC.   Over  a  year  ago  I  testified  before  two 
separate  Massachusetts  legislative  committees  advocating  the 
instituting  and  funding  of  an  effective  monitoring  system  by  the 
State  of  Massachusetts  to  be  sure  the  citizenry  is  protected  from 
the  operations  of  Pilgrim  I.   Legislation  was  introduced,  but  this 
week  it  died  in  the  final  hours  of  the  1987  legislative  session. 
Thus,  until  such  legislation  is  once  again  introduced  and  enacted, 
we  must  rely  on  the  NRC  to  police  the  operations  of  Pilgrim  I  -  a 
reliance  which  based  upon  past  experience  certainly  gives  me, 
and  I  presume  many  others,  little  comfort- 
Pilgrim  I  has  had  a  history  of  continued  unplanned 
radiation  releases  which  are  among  the  highest  in  the  nation. 
Again  and  again  we  see  reports  (such  as  the  1986  SALP  report)  of 
unplanned  radiation  releases;  only  with  diligent  digging  in  the 
morass  of  NRC  unpubliciSed  reports  do  we  see  the  true  extent  of 


17 


this  recurrent  publ ic  health  menace.   Now,  given  the  reports 
of  substantially  higher  than  avera<3e  incidences  of  cancer  in 
Plymouth  and  towns  downwind  of  the  plant,  the  do-nothing  approach 
by  the  State  of  Massachusetts  and  by  the  NRC  can  no  longer  be 
tolerated. 

This  history  of  Pilgrim  I  for  the  past  15  years  has  been 
one  of  citizen  groups  digging  through  the  voluminous  microfilm  and 
technical  reports,  most  usually  in  the  Public  Document  Room  in  the 
Plymouth  Public  Library,  to  find  the  obscure  reports  of  the  releases 
of  radiation  by  Pilgrim  I  into  the  Plymouth  environs  —  and  then 
trying  to  get  the  NRC  and  the  State  Department  of  Public  Health 
to  do  something  about  it.   To  date  our  efforts  have  been  singularly 
unsuccessful.   The  NRC  has  failed  miserably  over  the  years  —  both 
in  discharging  its  public  protection  function,  at  least  as  regards 
Pilgrim  I,  and  in  giving  the  public  any  comforting  perception  that 
it  is  fulfilling  this  function.   Operating  from  a  distance,  whether 
it  be  King  of  Prussia,  Pennsylvania  or  Washington,  D.C.,  the  NRC's 
typical  involvement  is  to  become  activated  after  receiving  a  report 
from  Boston  Edison,  then  to  dispatch  a  team  to  the  site,  listen  to 
Edison's  explanation,  and  then  generally  endorse  and  ratify  Edison's 
report  —  with  the  usual  conclusion,  without  any  further  investigation, 
that  the  public  health  was  not  adversely  impacted  by  the  incident. 

The  State  of  Massachusetts  likewise  has  failed  over  the 
years  to  effectively  monitor  the  plant's  operations.   And  it  is 
not  for  lack  of  trying  on  our  part  that  the  State  is  not  performing 
this  function.   Several  years  ago  as  a  result  of  federal  court 
litigation  involving  Pilgrim  I  brought  by  Plymouth  County 
Nuclear  Infromation  Committee,  the  State  Department  of  Public 


18 


Health  installed  several  thermoluminescent  dosimeters  ("TLD'S")  in 
Plymouth  and  surrounding  towns,  supposedly  to  monitor  the  release 
of  gamma  radiation  from  Pilgrim  I.   Unfortunately,  the  carrying 
out  of  this  function  has  proven  to  be  nearly  worthless  since  the 
devices  are  only  read  on  a  quarterly  basis  and  the  results  are 
virtually  hidden  from  public  view  —  and  even  worse,  no  attempt  is 
made  to  correlate  the  readings  of  these  devices  with  known  abnormal 
occurrences  at  the  plant  which  could  lead  to  offsite  releases 
despite  Edison's  predictable  self-serving  statements  that  all 
radiation  releases  are  contained  within  the  site  perimeter. 
Let  me  illustrate  this  fundamental  failure  of  the 
responsible  authorities  to  protect  the  citizens  of  the  South  Shore 
by  a  case  in  point  which  I  researched  myself.   In  June  1982,  Edison 
sent  a  detailed  report  to  the  NRC  Region  I  office  explaining  that 
highly  radioactive  resin  beads  and  particulate  matter,  that  had 
accumulated  over  an  extended  period  of  time,  was  found  t'o  have 
been  accidently  injected  into  the  duct-work  of  the  ventillation 
system,  and  from  there  to  the  outside  of  the  building.   This 
radioactive  material  was  discovered  on  the  roofs  of  several  of  the 
Pilgrim  I  buildings  and  on  the  ground.   The  NRC  Region  I  office 
dispatched  a  team  to  the  site  which  found  that  the  resin  had  been 
probably  released  through  the  reactor  building  vent-duct  which 
exhausts  to  the  atmosphere  at  an  elevation  of  approximately  100 
feet.   Ten  cubic  feet  of  this  highly  radioactive  resin  was  found 
in  the  Standby  Gas  Treatment  System  inlet  plenum  (the  source  of 
releases  to  the  atmosphere).   Despite  the  very  serious  nature 


19 


of  this  accident  and  the  potential  for  oCEsite  contamination  and 
the  carrying  away  of  radioactive  dust  by  the  winds,  no  effort  was 
made  to  read  the  off site  TLD's  (separate  sets  of  TLD's  are 
maintained  by  the  NRC  and  Boston  Edison,  in  addition  to  the  TLD's 
maintained  by  the  State),  and  correlate  such  readings  with  the 
observed  accident  at  the  plant.   Neither  the  NRC  nor  the  State 
ever  bothered  to  read  their  TLD's  to  see  if  Edison's  typically 
pollyannish  statement  that  no  radiation  escapted  off site  was  in 
fact  true.   This  failure  was  no  doubt  partly  due  to  the  fact  that 
^he  TLD  readings  do  not  become  available,  given  the  current 
practice  of  reading  them  quarterly,  until  several  weeks  after  any 
particular  release.   I  did  check  the  readings  and  the  results  are 
highly  significant.   For  instance,  in  the  summer  of  1982,  all  TLD 
locations,  as  measured  by  Edison,  the  NRC,  and  the  State,  showed  a 
large  rise  and  then  declined  by  about  the  same  percentage, 
indicating  a  consistent  pattern.   Likewise,  the  dose-rate 
decreased  with  distance  away  from  the  plant,  as  one  would  expect 
from  a  point-source,  the  zone  closest  to  the  plant  (0-0.16  miles) 
showing  the  largest  dose-rate,  thereby  confirming  that  the  accidental 
escape  of  highly  radioactive  wastes  reported  to  the  NRC  did  in 
fact  lead  to  offsite  contamination.   At  all  locations  as  far  away 
as  21  miles  to  the  northwest,  the  existing  background  radiation 
dose-rates  were  nearly  tripled  in  the  third  quarter  of  1982. 
Despite  the  potential  health  effects  of  this  release  of  radiation, 
a  member  of  the  NRC  inspection  team  who  had  visited  the  plant 
after  this  release  told  me  in  the  summer  of  1986  that  his  team 
had  not  road  the  TLD  data,  and  that  then,  some  four  years  after 
the  incident,  he  thought  that  these  readings  might  be  "worth 


20 


checking".   And  as  for  the  State  Department  of  Public  Health, 
suffice  it  to  say  that  it  took  me  many  long  hours  of  digging 
and  prodding  to  even  get  the  State  data  out  of  the  offices  of 
the  State  employee  who  collected  it  --  just  as  with  the  NRC  no 
attempt  whatsoever  had  been  made  by  the  Department  of  Public 
Health  to  correlate  this  data  with  the  accident. 

This  incident  and  the  lack  of  follow-up  by  the  responsible 
monitoring  authorities  illustrates  the  failure  of  the  system 
as  it  exists  today  to  protect  adequately  the  public  health  of 
the  citizenry  from  the  operation  of  Pilgrim  I  in  what  has  become 
the  fastest  growing  area  of  our  State.   The  remedy  for  this  failure 
is  starkly  obvious:   Either  the  NRC  or  the  State,  or  both  should 
gear  up,  with  the  necessary  manpower  and  equipment,  to  monitor 
the  day-to-day  operations  of  Pilgrim  I,  including  all  planned 
and  unplanned  releases  of  radiation  off-site,  on  a  regular  continuous 
basis  --  a  complete  system  of  radiation  detection  devices  should 
be  installed  off-site  at  various  distances  from  the  Plant,  and 
read  constantly  and  continuously  --  and  the  results  made  public. 
Such  a  system,  if  properly  designed  and  implemented,  could  add 
measurably  to  the  public's  confidence  that  its  safety  and  health 
were  being  duly  considered  and  protected. 

And  there  is  even  more  that  the  State  can  do  --  the 
State  of  Massachusetts  has  the  legal  power  to  set  its  own  level 
of  maximum  permissible  airborne  radioactive  emissions  from  Pilgrim 
I.   Under  Section  122  of  the  Clean  Air  Act  Amendments  of  1977, 
Congress  specifically  provided  that  the  States  have  the  legal 
authority  to  set  emission  standards  at  levels  which  are  more 


21 


stringent  than  standards  imposed  by  the  NRC  or  the  EPA.   And 
tho  NRC  itself  has  recognized  that  the  setting  of  such  standards 
by  a  State  might  even  prevent  the  construction  of  nuclear  plants 
or  halt  the  operation  of  existing  facilities. 

Meanwhile,  the  NRC  continues  to  rely  upon  standards 
of  permissible  radiation  releases  which  are  obsolete  and  understate 
by  many  times  the  actual  health  risks  posed  by  such  emissions 
of  radiation.   Obviously  these  permissible  radiation  standards 
should  be  updated  by  the  NRC,  but  having  seen  the  way  the  NRC 
operates  for  the  past  15  years,  I  have  little  hope  that  the  NRC  will 
do  so.     In  the  absence  of  NRC  action  it  is  imperative  that 
the  State  of  Massachusetts  act  in  this  critical  area,  to  design 
and  set  standards  of  radiation  releases  which  must  be  met  by 
nuclear  plants  operating  within  the  State  --  standards  that  will 
take  into  account  the  latest  of  scientific  evidence  on  the  health 
effects  of  low-level  radiation,  and  then  to  engineer  and  implement 
a  monitoring  system  to  ensure  that  Pilgrim  I  does  not  exceed 
such  standards,  and  if  it  does,  to  shut  it  down.   It  is  of  fundamental 
importance  to  the  mental  wellbeing  and  physical  health  of  the 
citizens  of  the  South  Shore  that  such  a  system  be  in  place  before 
the  plant  is  allowed  to  restart.   Ke  ask  the  support  of  your 
Committee  to  ensure  that  the  NRC  not  give  its  approval  to  Pilgrim 
restart  unless  and  until  an  effective  realtime  continuous  monitoring 
system,  run  either  by  the  NRC  or  the  State  of  Massachusetts  (not 
Boston  Edison)  has  been  fully  implemented. 


22 

The  Chairman.  I'm  going  to  come  back  to  some  questions  for  Mr. 
Abbott.  I  would  like  to  try  and  go  down  the  panel  first,  and  then 
come  back  with  some  questions.  I'll  ask  that  Ann  Waitkus-Arnold 
testify  next,  and  then  we'll  proceed  to  the  others,  she  is  the  Chair- 
woman of  the  Plymouth  Commission  on  the  Handicapped. 

Ms.  Waitkus-Arnold.  Thank  you,  Senator. 

The  Chairman.  Put  that  mike  a  little  closer. 

Ms.  Waitkus-Arnold.  Thank  you  for  the  opportunity  to  testify 
before  your  committee.  My  name  is  Ann  Waitkus-Arnold  and  I  rep- 
resent the  Massachusetts  Office  on  Handicap  Affairs,  and  chair- 
woman for  the  Disabled  Persons  for  the  Disabled  Advisory  Group 
on  Nuclear  Evacuations. 

I'm  also  the  chairperson  for  the  Public  Commission  on  Handicap 
Affairs,  Resource  Coordinator  for  We  the  People  and 

The  Chairman.  Slow  down  just  a  little,  Ann,  so  we  can  all 

Ms.  Waitkus-Arnold.  OK.  I'm  also  a  member  of  the  Massachu- 
setts Advisory  Council  on  Handicap  Affairs. 

The  purpose  of  the  advisory  group  is  to  make  recommendations 
to  be  used  by  the  Massachusetts  Civil  Defense  Agency  and  the  util- 
ities. This  is  a  crucial  first  step  in  a  statewide  effort  to  insure  that 
all  people  are  included  in  planning,  not  only  for  Pilgrim  I,  but  for 
Massachusetts  residents  affected  by  Yankee  Atomic  and  for 
Yankee  Rowe  nuclear  power  plants. 

In  my  official  capacity  for  the  State,  I  have  had  the  opportunity 
to  talk  with  representatives  from  Civil  Defense,  Department  of 
Public  Safety,  Boston  Edison,  Yankee  Atomic,  and  I've  addressed 
FEMA  and  the  NRC  on  several  occasions.  However,  I  have  seen 
little  evidence  of  any  real  efforts  to  insure  the  health  and  safety  of 
the  special  needs  of  populations  by  these  agencies.  They  may  give 
the  appearance  of  concern,  but  I  have  found  this  to  be  mostly  lip- 
service.  Government  assurances  to  protect  the  public  in  the  event 
of  an  accident  at  Pilgrim  I  have  been  deceptive  and  grossly  irre- 
sponsible. 

The  NRC  has  licensed  nuclear  facilities  that  have  not  included 
people  with  disabilities  and  pain.  And  only  recently  has  FEMA  con- 
cluded that  plans  for  Pilgrim  I  plant  are  not  adequate  for  people 
with  special  needs. 

The  State's  newest  revised  draft  of  October  1987,  developed  with 
the  assistance  of  Boston  Edison,  now  states  that  potassium  iodine 
will  be  stockpiled  for  use  for  those  who  will  be  left  behind,  instead 
of  including  all  citizens  in  actual  evacuations 

The  Chairman.  Would  you  like  to  expand  on  that  point? 

Ms.  Waitkus-Arnold.  OK. 

The  Chairman.  On  the  significance  of  storing  that  particular 
chemical. 

Ms.  Waitkus-Arnold.  They  will  be  storing  that  chemical — the 
chemical  protects  the  thyroid  gland  against  radioactive  iodine.  The 
problem  that  we  have  with  this  is  that  it  is  only  to  be  given  out  to 
people  in  nursing  homes,  hospitals  and 

The  Chairman.  Let's  get  a  little  more  complete  picture.  You  are 
talking  about  there  being  included  in  an  evacuation  plan  the  sug- 
gestion that  some  people  might  leave,  but  might  leave  those  who 
have  physical  disabilities  behind? 

Ms.  Waitkus-Arnold.  Right. 


23 

The  Chairman.  People  in  nursing  homes  or  who  have  other 
physical  disabilities.  They  are  going  to  be  inoculated  with  this,  or 
they  take  a  pill.  They  take  a  pill,  and  they  take  whatever  radiation 
there  is.  The  other  people  have  effectively  left,  and  they  leave  the 
handicapped  or  physically  disabled — or  physically  challenged,  as 
my  son  would  say — behind,  to  take  their  pills  and  hope  for  the 
best? 

Ms.  Waitkus-Arnold.  Right.  This  is  a  drug  that  can  cause  severe 
allergic  reactions,  hemorrhaging,  and  even  death. 

Mr.  Chairman.  Do  you  have  any  instant  reaction  to  that  type  of 
an  evacuation  plan?  I  can't  let  that  quite  slide  by  so  quickly. 

Ms.  Waitkus-Arnold.  My  instant  reaction  is  anger,  discrimina- 
tion, and  I  think  it  is  a  very  inhuman  way  to  treat  people,  especial- 
ly elders  and  disabled.  Those  are  the  only  people  targeted  out  for 
this  particular  type  of  treatment. 

The  Chairman.  The  elderly  and  the  disabled? 

Ms.  Waitkus-Arnold.  Elderly  and  disabled.  That  means  that  we 
have  a  discriminatory  system  in  our  country  today. 

In  my  opinion  and  the  opinion  of  the  advisory  group,  Edison  has 
spent  a  great  deal  of  time  lulling  people  into  a  false  sense  of  securi- 
ty, and  h£is  consistently  been  misleading  and  deceptive  on  the 
issues  of  special  needs. 

One  example  is  a  special  needs  survey  done  by  Edison  at  the  in- 
sistence of  our  disability  group.  The  purpose  of  the  survey  was  to 
identify  people  who  will  need  assistance  during  evacuation;  unfor- 
tunately, they  ignored  our  suggestions  and  offers  of  assistance.  The 
resulting  survey  was  designed  in  such  a  way  as  to  exclude  most  of 
the  people  with  disabilities. 

Consequently,  there  is  a  stunning  discrepancy  between  the  1986 
Disability  Census  figure,  which  shows  4,000  people  in  Plymouth 
alone  with  severe  limitations  and  the  utilities'  figures  showing  only 
474.  Edison  then  incorporated  these  erroneous  figures  into  their 
new  evacuation  time  estimates  of  special  needs  population. 

The  Chairman.  As  I  understand,  partially  because  many  of  those 
who  have  physical  disabilities  don't  report  them;  is  that  right? 

Ms.  Waitkus-Arnold.  No.  It's  because  the  survey  was  kind  of  a 
bogus  survey.  It  wasn't  sent  out  to  people — it  wasn't  sent  out  to 
any  handicapped  or  elderly  house.  They  refused  to  send  it  out  to 
every  household  in  the  town  of  Plymouth.  It  wasn't  understandable 
by  many  disabled  people;  elders  who  had  no  idea  that  the  service 
pertained  to  them  because  it  spoke  about  severe  disabilities,  and  it 
did  not  include  a  lot  of  questions  about  many  disabilities.  Obvious- 
ly, if  one  is  blind,  one  would  not  be  able  to  fill  out  the  survey. 

In  addition,  we  have  advocated  for  2  years  that  Edison  comply 
with  NRC's  regulations  to  notify  and  alert  all  segment  of  the  com- 
munity in  case  of  an  accident  of  Pilgrim  I.  This  includes  people 
who  are  deaf  and  hard  of  hearing. 

I  have  testified  before  the  NEC  several  times  on  this  issue;  how- 
ever, proper  action  has  not  been  taken  to  obtain  and  distribute  spe- 
cial equipment  to  the  420  residents  who  have  requested  it  from 
Boston  Edison.  I  feel  that  the  NRC  is  complicit  in  its  violations  of 
federal  law  because  they  have  been  aware  of  this  violation,  but 
have  taken  no  action  to  make  Boston  Edison  comply. 


24 

With  few  exceptions,  there  appears  to  be  an  attitude  from  the 
Federal  Government  on  down  that  some  elderly  and  disabled 
people  are  not  worth  consideration  because  exclusion  is  permitted. 
The  quality  of  our  Government  is  reflected  by  the  way  the  Govern- 
ment deals  with  its  citizens  that  are  in  need  of  assistance,  and 
until  this  attitude  changes,  disabled  people  will  be  continued  to  be 
treated  as  second-class  citizens.  I'm  talking  about  people  who  we 
love  and  care  about,  our  children,  parents,  grandparents  who  may 
have  hearing,  vision  or  physical  disabilities,  the  thousands  of  elder- 
ly who  will  need  assistance  in  an  evacuation;  our  disabled  veterans 
in  homes  and  hospitals  and  the  many  retarded  persons  in  group 
homes,  who  may  not  even  recognize  that  an  emergency  exists. 
What  will  happen  to  them  during  an  emergency? 

We  are  not  asking  for  special  treatment,  only  equal  treatment. 
Failure  to  include  elderly  and  disabled  in  planning  is  deprivation 
under  the  equal  treatment  under  the  4th  and  14th  amendments. 
We  are  not  sajdng  we  ought  to  come  first.  We  just  want  the  same 
chance  to  escape  as  everyone  else  has.  Basic  civil  rights  are  the 
birthright  of  all  Americans  and  second  class  citizenship  should  no 
longer  be  allowed.  Realistic  and  humane  emergency  plans  must  be 
developed  for  all  people  and  every  town  and  village  from  Cape  Cod 
to  the  borders  of  New  Hampshire  affected  by  this  plant.  Unless  a 
workable  plan  can  be  designed  for  everybody,  and  until  such  a  plan 
can  be  tested  and  implemented.  Pilgrim  I  should  remain  closed. 

There  have  been  serious  incidents  which  reveal  the  GE  contain- 
ment systems,  like  the  Pilgrim  I  containment,  had  an  unsafe 
design,  making  it  very  unlikely  to  withstand  a  major  accident.  This 
report  was  kept  secret  by  GE  and  the  NRC  for  12  years.  In  addi- 
tion, the  report  stated  that  radioactive  and  chemical  waste  in 
Pl5anouth  by  Boston  Edison  was  duly  reported  to  State  and  Federal 
authorities  and  has  yet  to  be  investigated  after  7  years.  We  feel 
that  waiting  7  years  is  7  years  too  long  to  find  out  whether  our  soil 
and  water  have  been  contaminated. 

In  light  of  the  above  examples,  there  must  be  an  immediate  mor- 
atorium on  the  operation  of  all  nuclear  plants  which  affect  Massa- 
chusetts residents,  and  Congress  must  hold  a  full  investigation  into 
why  the  NRC  has  failed  to  protect  the  health  and  safety  of  elderly 
and  disabled  people  as  well  as  the  rest  of  the  general  public.  Thank 
you  very  much  for  inviting  me  to  speak. 

The  Chairman.  We'll  come  back  to  you.  Do  you  know  of  your 
own  knowledge  whether  other  evacuation  plans  treat  the  handi- 
capped like  this? 

Ms.  Waitkus-Arnold.  Jerome  Plant. 

The  Chairman.  Where  they  have  similar  kinds  of 

Ms.  Waitkus-Arnold.  Exactly. 

[The  prepared  statement  of  Ms.  Waitkus-Arnold  follows:] 


^&* 


25 


The  Disabled  Persons'  Advisory  Group 
on 
Nuclear  Evacuation 


Ann  Waitkus-Arnold  Post  Office  Box  3803  617-747-4574 

Chair  Plymouth, MA  02361  Voice  &TDD 


Honorable  Edward  M.  Kennedy 
2400  J.F.K.  Federal  Building 
Boston^  Ma.  02108 

Mr  Chairman; 

My  name  is  Ann  Waitkus-Arnold,  and  I  represent  the  Massachusetts 

Office  on  Handicapped  Affairs  as  the  Chairwoman  of  the  Disabled  Persons' 
Advisory  Group  on  Nuclear  Evacuation.  I  am  also  the  Chairperson  of  the 
Plymouth  Commission  on  Handicapped  Affairs,  Special  Needs  Co-ordinator 
for  We  the  People, Inc.  of  the  United  States,  and  a  member  of  the  Plymouth 
Nuclear  Affairs  Committee  and  the  Massachusetts  Advisory  Council  on 
Handicapped  Affairs.  The  purpose  of  the  Advisory  Group  is  to  make  re- 
commendations to  be  utilized  by  the  Massachusetts  Civil  Defense  Agency 
and  the  Utilities.  This  is  a  crucial  first  step  in  a  statewide  effort 
to  insure  that  ail  people  are  included  in  planning,  not  only  for  Pilgrim 
I,  but  for  Massachusetts  residents  affected  by  Yankee  Atomic  in  Rowe,  and 
the  Vermont  Yankee  Nuclear  Power  Plant.  In  my  official  capacity  for  the 
State,  I  have  had  the  opportunity  to  work  with  representatives  from 
M.C.D.A.,  the  Departmentof  Public  Safety, the  Boston  Edison  Company, 
Yankee  Atomic,  and  I  have  addressed  the  Federal  Emergency  Management  Ag- 
ency and  the  Nuclear  Regulatory  Commission  on  several  occassions. 

However,  I  have  seen  little  evidence  of  any  real  efforts  to  insure 
the  health  and  safety  of  the  Special  Needs  Populations  by  these  agencies. 
They  may  give  the  appearance  of  concern,  but  I  have  found  this  to  be 
mostly  Up  service.  Government  assurances  to  protect  the  public  in  the 


26 


(2) 

event  of  an  accident  at  Pilgrim  I  have  been  deceptive  and  grossly  irr- 
esponsible. The  NRC  has  licensed  Nuclear  facilities  that  have  not  in- 
cluded people  with  disabilities  in  Planning,  and.  only  recently  has 
FEMA  concluded  that  plans  for  the  Pilgrim  I  Plant  are  not  adequate  for 
people  with  Special  Needs  although  I  realize  the  NRC  is  not  obliged 
to  take  advice  from  FEMA.  The  States  newest  revised  Plan,  of  October. 
1987.  developed  with  the  assistance  of  Boston  Edison,  now  states  that 
Potassium  Iodide  will  be  stockpiled  for  use  by  those  who  will  be  left 
behind,  instead  of  including  all  citizens  in  actual  Evacuations.  Who 
are  these  people  who  will  be  left  behind?  -  People  in  Hospitals.  Nurs- 
ing Homes  and  Detention  Centers,  including  the  Plymouth  County  Farm. 
This  proposed  use  of  a  drug  which  can  cause  severe  allergic  reactions, 
hemmorrhaging.  and  even  death,  is  inhumane  and  totally  unacceptable. 

In  my  opinion,  and  in  the  opinion  of  the  Advisory  Group.  BECo 
has  spent  a  great  deal  of  time  and  money  lulling  people  into  a  false 
sense  of  security,  and  has  been  consistently  misleading  and  deceptive 
on  these  issues.  One  example  is  the  Special  Needs  Survey,  done  by  BECo. 
at  the  insistance  of  the  Disabiltiy  Group.  This  group  included  people 
with  disabilities,  representatives  from  Independent  Living  Centers, 
and  State  Agencies.  The  purpose  of  that  Survey  was  to  identify  people 
who  will  need  assistance  during  Evacuation.  Unfortunately,  they  refused 
our  input andParticipation  in  developing  a  workable  document. and.  instead. 

the  Survey  was  not  done  in  good  faith,  and  did  not  collect  the  needed 
information. Consequently,  there  was  a  stunning  discrepancy  between  the 
1986  Disability  Census  Figures  showing  4.000  people  with  severe  limit- 
ations in  Plymouth  alone,  and  the  Utilities'  figures  showing  only  ^7^. 
BECo  then  incorporated  their  erroneous  figures  into  their  new  Evacuation 
Time  Estimates  for  Special  Needs  Populations,  thereby  calling  into 
question  the  validity  of  this  document. 


27 


(3) 


In  addition,  we  have  been  advocating  for  two  years  that  BECo  comply 
With  NRC  Regulation  to  "notify  and  Alert  all  segments  of  the  community" 
in  case  of  an  accident  at  Pilgrim  I.  This  includes  people  who  are  deaf 
and  hard-of-hearing.  I  have  testified  before  the  NRC  several  times  on 
this  issue,  however,  proper  action  has  not  been  taken  to  obtain  and 
distribute  special  equipment  to  the  421  residents  who  have  requested 
It  from  BECo.  I  feel  the  NRC  is  complicit  in  this  violation  of  Federal 
Law  because  they  have  been  made  aware  of  this  violation,  but  have  taken 
no  action  to  make  BECo  comply. 

With  few  exceptions,  there  appears  to  be  an  attitude  from  the  Fed- 
eral Government  on  down  that  elderly  and  disabled  people  are  not  worth 
consideration,  because  exclusion  is  pisrmitted.       This  is  defacto 
discrimination.  The  quality  of  our  Government  is  reflected  by  the  way 
the  Government  deals  with  it's  citizens  who  are  in  need  of  assistance, 
and,  until  this  discriminatory  attitude  changes,  disabled  people  will 
continue  to  be  treated  as  second  class  citizens.  I'm  talking  about  people 
whom  we  love  and  care  about  -  our  children,  parents  and  grandparents 
who  may  have  hearing,  vision,  or  physical  disabilities,  the  thousands 
of  elderly  who  will  need  special  assistance,  our  disabled  veterans  in 
homes  and  hospitals,  and  the  many  retarded  persons  in  Group  Homes,  who 
may  not  even  recognize  that  an  emergency  exists.   What  will  happen  to 
them  during  an  Emergency?  These  people  are  human  beings  who  are  impor- 
tant to  our  communities.  We  are  not  asking  for  special  treatment,  only 
equal  treatment.  Failure  to  include  elders  and  disabled  citizens  in  Ev- 
acuation Planning  is  depravation  of  Equal  Treatment  under  the  Fifth  and 
Fourteenth  Amendments,  we're  not  saying  we  want  to  be  first  -  we  just 
want  the  same  chance  to  escape  as  everyone  else,  however  small  that 
may  be.  Basic  Civil  Rights  are  the  birthright  of  all  Americans,  and 
second  class  citizenship  must  not  be  allowed.  Realistic  and  humane 


28 


(4) 


Emergency  Plans  must  be  developed  for  all  people  in  every  town  and 
village  from  Cape  Cod  to  the  borders  of  New  Hampshire!  Unless  s  work- 
able plan  can  be  designed  for  everyone,  and  until  such  a  plan  can  be 
tested  and  implemented.  Pilgrim  I  must  remain  closed. 

There  have  been  serious  incidents,  including  the  Reed  Report, 
which  revealed  that  GE  containments,  like  the  Pilgrim  I  vessel, 
have  an  unsafe  design  making  it  very  unlikely  to  withstand  a  major 
accident.  This  report  was  kept  secret  by  GE  and  the  NRC  for  12  years! 
In  addition,  the  reported  dumping  of  radioactive  and  chemical  waste  in 
Plymouth  by  BECo.  duly  reported  to  State  and  Federal  Authorities,  has 
yet  to  be  investigated  after  seven  years.  We  feel  that  waiting  seven 
years  is  seven  years  too  long  to  find  out  whether  our  soil  and  ground 
water  have  been  contaminated. 

In  light  of  the  above  examples,  there  must  be  an  immediate 
Moratorium  on  the  operation  of  all  Nuclear  Plants  which  affect  Mass^ 
residents,  and  Congress  must  hold  a  Full  Investigation  into  why  the 
NRC  has  failed  to  protect  the  health  and  safety  of  Elderly  and  Disabled 
people,  as  well  as  the  rest  of  the  general  public. 

Thank  you.  Mr.  Chairman,  for  inviting  me  to  speak  on  these  issues, 
and  1  would  be  happy  to  answer  any  questions  you  might  have. 

Ann  Waitkus-Arnold 
Chairwoman 


29 


^/le  J^dX/u/'/on  ^/ace  3^om  /SOS 

^oi/o/i  0^06' 


MICHAEL  S.  DUKAKIS 
Governor 

727-7440 
JIM  GLEICH  Vccc  i  TDD 

Director  1-8O0.322.2O20 

Voice  &  TDD 


FOR  IMMEDIATE  RELEASE  CONTACT:  LORRAINE  GREIFF 

DECEMBER  4,  1987  617-727-7400 

PRESS  RELEASE 

ANN  WAITKUS-ARNOLD  APPOINTED  CHAIRWOMAN  OF  DISABLED  PERSONS 
ADVISORY  GROUP  ON  NUCLEAR  EVACUATION 


AWN  WAITKUS-ARNOLD  OF  PLYMOUTH  WAS  RECENTLY  APPOINTED  BY  THE 
MASSACHUSETTS  OFFICE  OF  HANDICAPPED  AFFAIRS  TO  BE  CHAIRWOMAN 
OF  THE  DISABLED  PERSONS  ADVISORY  GROUP  ON  NUCLEAR  EVALUATION. 
THE  PURPOSE  OF  THE  ADVISORY  COMMITTEE  IS  TO  MAKE  RECOMMENDATIONS 
TO  THE  STATE-WIDE  TASK  FORCE  ON  CIVIL  DEFENSE  TO  INSURE 
INCLUSION  IN  EVACUATION  PLANNING  FOR  PEOPLE  WHO  ARE  ELDERLY 
AND /OR  DISABLED  IN  ALL  AREAS  OF  THE  STATE  NEAR  NUCLEAR  POWER 
STATIONS. 

THE  ADVISORY  GROUP  CONSISTS  OF  ADVOCATES  WHO  ARE  DISABLED 
FROM  THROUGHOUT  THE  STATE.  IT  HAS  MET  WITH  BOSTON  EDISON, 
YANKEE  ATOMIC,  AND  THE  MASSACHUSETTS  CIVIL  DEFENSE  AGENCY. 
IT  IS  EXPECTED  TO  RECOMMEND  THE  HIRING  OF  A  PROFESSIONAL 
CONSULTANT  TO  RESEARCH  THE  DEMOGRAPHICS  OF  PEOPLE  WITH 
DISABILITIES  NEAR  NUCLEAR  POWER  PLANTS;  TO  DETERMINE  THEIR 
NEEDS  IN  THE  EVENT  OF  AN  EMERGENCY;  TO  DETERMINE  WHICH  PEOPLE 
IF  ANY,  CANNOT  BE  EVACUATED;  AND  TO  DETERMINE  THE  ATTENDENT 
RISKS  IN  REMAINING  WHERE  THEY  ARE. 

"THIS  ADVISORY  GROUP  IS  A  CRITICAL  FIRST  STEP  IN  THE  STATEWIDE 
EFFORT  TO  DEAL  WITH  EMERGENCY  EVACUATION  PROCEDURES  FOR  ALL 
PEOPLE,"  ACCORDING  TO  JIM  GLEICH,  DIRECTOR  OF  THE  MASSACHUSETTS 
OFFICE  OF  HANDICAPPED  AFFAIRS. 


30 

The  Chairman.  Mr.  Johnson. 

Mr.  Johnson.  Thank  you,  Senator  for  this  opportunity  to  testify 
before  the  committee. 

My  name  is  Neil  Johnson.  I'm  the  chairman  of  the  Duxbury  Citi- 
zens Committee  on  Nuclear  Matters,  and  a  member  of  the  Duxbury 
Emergency  Response  Committee  also.  I  am  a  registered  profession- 
al engineer  and  have  design  experience  working  on  nuclear  power 
plants  as  a  licensing,  environmental  and  structural  engineer. 

I  would  like  to  address  three  areas:  switchyard  and  emergency 
diesel  generators,  overpressurization  failure  and  direct  torus  vent- 
ing and  stress  corrosion  cracking. 

First,  the  switchyard  and  emergency  diesel  generators.  On  No- 
vember 12,  1987,  at  approximately  2:10  a.m.,  the  Pilgrim  nuclear 
power  station  experienced  a  complete  loss  of  offsite  power,  LOOP, 
during  adverse  Weather  conditions.  This  resulted  in  a  start-up  of 
two  emergency  diesel  generators.  Prior  to  the  restoration  of  offsite 
power  at  11:15  p.m.  on  the  same  day,  one  of  the  diesel  generators 
had  to  be  shut  down,  leaving  only  one  diesel  generator  operating. 
The  event  was  not  given  a  licensee  emergency  classification  by  the 
NRC,  as  the  plant  was  in  cold  shutdown. 

It  was  reported  that  the  loss  of  offsite  power  was  associated  with 
icing  in  the  switchyard.  I'm  concerned  that  similar  problems  with 
the  plant  operating  could  occur  in  the  future  that  could  result  in 
more  serious  consequences. 

Since  June  of  1972,  there  have  been  20  instances  of  loss  of  the 
345  kv  offsite  system  and  four  instances  of  loss  of  both  the  345  kv 
and  the  23  kv  offsite  system.  This  would  be  considered  four  LOOP 
events,  L-O-O-P. 

I  believe  that  prior  to  restart,  the  NRC  should  review  the  switch- 
yard and  emergency  diesel  generators  as  a  system  and  assure  the 
public  that  the  integrity  of  this  system  can  be  maintained  under 
adverse  conditions. 

Based  on  the  recent  diesel  generators  and  switchyard  problems,  I 
believe  that  the  NRC  should  require  completion  of  the  installation 
of  the  new  2,000  kw  blackout  diesel  prior  to  the  restart. 

The  conclusion  of  the  NRC  Augmented  Inspection  Team  review 
of  the  November  12  incident,  the  loss  of  the  offsite  power  was  that 
the  inoperability  of  the  B  emergency  diesel  generator  resulted  from 
the  performance  of  maintenance  using  inadequate  or  incomplete 
maintenance  procedures. 

1  believe  that  the  NRC  should  assure  the  public  that  BECO  will 
more  aggressively  pursue  courses  of  action  to  mitigate  mechanical 
problems  such  as  those  experienced  on  the  B  emergency  diesel  gen- 
erator. 

The  next  topic  is  on  overpressurization  failure  and  direct  torus 
venting. 

The  Chairman.  Let  me  just  briefly  ask  you  what  would  have 
been  the  effect  if  you  had  a  diesel  generator  fail,  if  the  plant  had 
been  on-line? 

Mr.  Johnson.  Had  the  last  diesel  generator  failed  and  the  plant 
been  on-line,  it  would  have  been  a  station  blackout.  There  is — there 
are  some  emergency  batteries  that  would  keep  things  going  for  a 
short  time.  But  without  offsite  power  and  without  the  two  diesel 
generators,  you  have  a  station  blackout. 


31 

The  Chairman.  What  does  that  mean,  station  blackout? 

Mr.  Johnson.  That  means  you  don't  have  power  to  run  the  serv- 
ice water  system  and  your  systems  required  for  safe  shutdown. 

The  Chairman.  So  the  systems  for  safety  would  have  been  effec- 
tively shut  down;  is  that  what  you  are  saying? 

Mr.  Johnson.  Yes.  There  are  some  batteries  that  would  keep 
things  going  for  a  period  of  time.  OK,  overpressurization  failure 
and  direct  torus  venting.  I  understand  that  severe  accidents  in  the 
extreme  can  generate  pressures  of  more  than  twice  the  design  pres- 
sure of  a  Mark  I  containment  structure  similar  to  the  one  at  Pil- 
grim and  could  cause  containment  rupture.  One  core  damage  pre- 
vention strategy  utilized  is  containment  venting  of  excess  pressure 
gradually.  I  have  a  sketch  attached  for  those  who  would  like  to  see. 
This  is  achieved  by  bubbling  the  release  from  the  gas  treatment 
system — excuse  me,  from  the  reactor  dry  well  through  the  wet  well 
on  through  the  standby  gas  treatment  system,  the  SBGT,  where  re- 
maining radioactive  iodine  and  particulates  are  removed,  finally 
venting  out  through  the  main  plant  stack.  Incidently,  the  standby 
gas  treatment  system  remained  out  of  service  from  1984  through  at 
least  1986  at  Pilgrim. 

It  is  also  my  understanding  that  the  existing  vent  duct  work  as- 
sociated with  the  standby  gas  treatment  system  is  of  fairly  light 
gauge  and  may  be  broached  in  accident  venting.  Therefore,  the  in- 
stallation of  the  direct  torus  vent  system,  which  provides  a  direct 
vent  path,  with  heavier  gauge  pipe  around  the  standby  gas  treat- 
ment system  was  proposed  at  Pilgrim.  Installation  of  this  system 
was  begun,  but  not  completed  due  to  a  lack  of  approval  by  the 
NRC. 

I  believe  that  the  NRC  should  be  concerned  about  the  effects  of 
secondary  release  of  radioactive  gas  into  the  reactor  building  in  the 
event  of  duct  work  failure.  Also,  if  in  the  future,  the  NRC  approves 
the  direct  torus  venting  system,  I  believe  that  they  should  review 
the  operation  of  the  manual  override,  which  would  allow  the  opera- 
tor to  manually  override  switches  to  allow  venting  to  continue  even 
with  high  radiation  in  the  torus  vapor  space.  I  know  that's  fairly 
technical,  but 

The  Chairman.  That  is  very  technical.  [Laughter.] 

I'll  give  you  30  seconds  to  translate  it  for  everyone.  Let's  just 
take  a  minute  and  give  us  the  essence  of  it,  if  you  would. 

Mr.  Johnson.  OK.  With  a  station  blackout,  there  are  spray  sys-~^ 
tems  that  would  cool  the  reactor.  However,  if  those  fail  due  to  no 
power  or  some  other  problem,  then  there  is  direct  torus  venting  or 
a  venting  out  of  the  dry  well  portion  of  the  containment  through 
the  wet  well. 

The  Chairman.  As  I  understand  it,  they  don't  have  torus  vent- 
ing; they  want  to  have  torus  venting? 

Mr.  Johnson.  Yes.  They  have  started  installation  of  torus  vent- 
ing which  would  bypass  the  standby  gas  treatment  system.  That 
has  not  been  given  approval  by  the  NRC. 

The  Chairman.  Edison  desired  to  design  a  standby  system,  but 
NRC  has  not  approved  that? 

Mr.  Johnson.  They  felt  it  was  conflicting — I  forget  the  exact  ter- 
minology. Conflicting  safety  issues,  I  think  is  the  terminology. 


32 

The  Chairman.  Some  translate  that  as  possibly  the  fact  that  if 
Boston  Edison  is  prepared  to  put  it  in,  that  might  suggest  that 
others  should  put  it  in  their  plants,  and  others  might  not  be  willing 
to  do  it.  I  don't  know  if  that's  fair. 

Mr.  Johnson.  I'm  also  a  bit  concerned  in  that  there  is  a  manual 
override  in  the  event  of  high  pressure  and  high  radiation  that 
would  allow  an  operator  to  open  a  valve  to  bypass  the  SBGT  and  to 
go  right  out  to  the  atmosphere  via  the  main  plant  stack. 

[The  prepared  statement  of  Mr.  Johnson  follows:] 


33 


STATEMENT  OF  NEIL  JOHNSON 


Good  evening.  My  name  is  Neil  Johnson,  and  I,m  the  Chairman  of 
the  Duxbury  Citizens  Committee  on  Nuclear  Matters  and  a  mem.ber  ;f 
the  Duxbury  Emergency  Response  Comm.ittee.  I  am  a  registered 
Professional  Engineer  and  have  13  years  of  design  experience 
working  on  nuclear  power  plants  as  a  Licensing,  Environmental  and 
Structural  Engineer.  I,d  like  to  address  3  areas  -  Switchyard 
and  Emergency  Diesel  Generators,  Overpressurizat ion  Failure  and 
Direct  Torus  Venting  and  Stress  Corrosion  Cracking. 

Swit  :hyard  and  Emergency  Diesel  Generators 


On  November  12,1987  at  approximately  2:10  AM,  the  Pilgrir.  Nuclear 
Power  Station  experienced  a  complete  loss  of  offsite  power  (LOOP, 
during  adverse  weather  conditions.  This  resulted  in  startup  of 
the  two  emergency  diesel  generators.  Prior  to  the  restoration  of 
offsite  power  at  11:15  P.M.  on  the  same  day,  one  of  the  diesel 
generators  had  to  be  shut  down  leaving  only  one  diesel  generator 
operating.  The  event  was  not  given  a  licensee  Emergency  Class- 
ification by  the  NRC  as  the  plant  was  in  cold  shutdown. 

It  was  reported  that  the  loss  of  offsite  power  was  associated 
with  icing  in  the  switchyard.  I  am  concerned  that  sir-.ilar 
problems  with  the  plant  operating  could  occur  in  the  future  that 
could  result  in  more  serious  consequences. 


Since  June  jf  19''2  there  have  been  20  instances  of  loss  of  the 
345  kV  offsite  system  and  4  instances  of  loss  of  both  the  345  >V 
and  the  23  kV  offsite  systems  (  4  LOOP  events  ) . 

I  believe,  that  prior  to  restart,  the  NRC  should  review  the  swit- 
chyard and  emergency  diesel  generators  as  a  system,  and  assure 
the  public  that  the  integrity  of  this  system  can  be  maintained 
under  adverse  conditions. 

Based  on  the  recent  diesel  generator  and  switchyard  problems  1 
believe  that  the  NRC  should  require  completion  of  the  installa- 
tion of  the  new  2000  KW  blackout  diesel  prior  to  the  restart. 

The  conclusion  of  the  Augmented  Inspection  Tea.m  review  of  tr.e 
November  12,  1987  loss  of  offsite  power  was  that  the  ir.- 
operability  of  the  "B"  emergency  diesel  generator  resulted  frorr. 
the  performance  of  maintenance  using  inadequate  or  incomplete 
maintenance  procedures. 

I  believe  that  the  NRC  should  assure  the  public  that  BECO  will 
m^ore  aggressively  pursue  courses  of  action  to  mitigate  mechanical 
problems  such  as  those  experienced  on  the  "B"  e.mergency  diesel 
generator? 


34 


Overpressure  Failure  and  Direct  Torus  Venting 

I  understand  that  severe  accidents  in  the  extreme  can  generate 
pressures  of  T.ore  than  twice  the  design  pressure  of  a  Mark  I  con- 
tainment structure  similar  to  the  one  at  Pilgrim  and  could  cause 
containment  rupture.  One  core  damage  prevention  strategy  util- 
ized IS  containm.ent  venting  of  excess  pressure  gradually.  (see 
attached  sketch) .  This  is  achieved  by  bubbling  the  release  from 
the  reactor  drywell ,  through  the  wet  well,  on  through  the  Standby 
Gas  Treatment  System  (SBGT)  where  remaining  radioactive  iodine 
and  particulates  are  removed,  finally  venting  out  through  the 
main  plant  stack.  Incidentally,  the  Standby  Gas  Treat.-p.ent  System 
remained  out  of  service  from  1984  through  at  least  1985  at 
Pilgrim. 

It  is  also  my  understanding  that  the  existing  vent  ductwork  as- 
sociated with  the  Standby  Gas  Treatment  System  is  of  fairly  light 
gague  and  may  be  broached  in  accident  venting.  Therefore  the 
installation  of  a  Direct  Torus  Vent  System  which  provides  a 
direct  vent  path,  with  heavier  gauge  pipe,  around  the  Standby  Gas 
Treatment  System,  was  proposed  at  Pilgrim.  Installation  of  this 
system,  was  begun  but  not  completed  due  to  a  lack  of  approval  by 
the  NRC. 

I  believe  that  the  MRC  should  be  concerned  about  the  effects  of 
secondary  release  of  radioactive  gas  into  the  reactor  building  in 
the  event  of  a  ductwork  failure.  Also,  if  in  the  future  the  MRC 
approves  the  Direct  Torus  Venting  System,  I  believe  that  they 
should  review  the  operation  of  the  raanual  overide  which  would  al- 
low the  operator  to  manually  overide  switches  to  allow  venting  to 
continue  even  with  high  radiation  in  the  Torus  vapor  space. 


35 


36 


stress  Corrosion  Cracking 


The  1987  update  of  the  summary  of  findings  and  recommondations  in 
the  Reed  Report  -  19''5  -  General  Electric  Corporation  states  that 
stress  corrosion  cracking  (  SCC  )  is  a  complex,  industry-wide 
problem  affecting  both  BWR ' s  and  PWR ' s ,  and  relates  fundamentally 
to  the  harsh  environment  in  which  components  and  piping  must 
operate  in  nuclear  power  plants. 

In  December  of  1983,  the  NRC  ordered  the  lisensee  to  shut  down 
and  inspect  the  recirculating  system  piping  for  mtegranular 
stress  corrosion  cracking.  The  licensee  replaced  the  recirculat- 
ing system  piping  and  was  authorized  to  restart  in  December  1984. 

I  recommend  that  the  NRC  make  sure  that  all  recommendations  by 
General  Electric  to  upgrade  BWR  reliability  as  i.mpacted  by  stress 
corrosion  cracking  have  been  implemented  at  Pilgrim  so  that  this 
condition  does  not  reoccur  in  the  future. 


37 


Questions 

In  The  restart  plan  reference  is  made  to  the  fact  that  4  shifts 
of  operators  will  be  available  during  startup  and  power  ascension 
and  that  6  shifts  will  be  available  in  the  longer  term.  Since  4 
shifts  are  not  able  to  cover  the  work  week  of  21  shifts  without 
regular  use  of  overtime  (  50  %  overtime  ) ,  how  soon  will  Edison 
have  6  shifts  available? 

Would  the  NRC  please  obtain  and  make  available  to  the  public  the 
records  of  hours  worked  by  the  operators  on  duty  on  November  12, 
1987.  A  two  week  period  prior  to  and  including  November  12,  1987 
would  be  appropriate. 

The  restart  plan  states  that  "It  is  not  intended  as  a  go/no  go 
acceptance  criteria.  They  may  proceed  if  their  performance  falls 
reasonably  within  a  goal?"  Who  determines  if  their  performance 
falls  within  a  goal  and  what  criteria  is  used? 

V/e  would  like  the  NRC  to  discuss  decommissioning  costs  and 
methods.  How  can  we  be  assured  that  deccmmissioning  will  be 
adequately  funded  for  Pilgrim  I  when  it  has  outlived  its 
usefulness?  What  lessons  has  the  NRC  learned  from  the  Ship- 
pingport  Pa.  decommissioning? 

What  will  the  NRC  do  to  insure  that  groundwater  ingress  both 
through  the  seams  in  the  Process  Building  wall  and  through  the 
conduit  penetration  for  the  switchyard  sump  pump  is  corrected? 


38 

The  Chairman.  OK.  We'll  go  to  Mary  Ott.  We're  trying  to  open 
up  the  back  here  so  that  we  can  have  some  of  our  other  guests  go 
up  on  the  stage.  It  might  be  somewhat  uncomfortable,  but  at  least 
they'll  be  able  to  observe. 

I'm  informed  that  there  is  another  room  here  where  they  are 
covering  this  through  a  TV  monitor,  I'm  informed  the  back  is 
loaded  with  equipment.  I  don't  know  where  the  fire  marshall  is, 
but  we'll  check.  Anyway,  we'll  move  on. 

Mary  Ott,  we'll  hear  from  you. 

Ms.  Ott.  Good  evening.  Senator  Kennedy.  We  commend  you  for 
calling  this  important  meeting  and  are  very  grateful  for  the  oppor- 
tunity to  express  our  deepening  concern  about  the  health  and 
safety  impact  with  the  restart  of  Pilgrim,  and  further  at  the  failure 
of  the  Nuclear  Regulatory  Commission  to  perform  its  sanctioned 
duty  to  regulate  this  utility. 

Our  concerns  encompass  Pilgrims  flawed  GE  Mark  I  contain- 
ment, its  poor  management  history,  the  lack  of  evacuation  plans 
for  area  residents,  the  threat  posed  by  the  continued  stockpiling  of 
tons  of  nuclear  waste  on  site,  the  alarming  increase  in  cancer  in 
the  five  towns  downwind,  and  finally,  the  credibility  of  the  Boston 
Edison  Co.  and  its  regulator,  the  NRC. 

Although  a  conclusive  link  has  not  been  found.  Pilgrim's  history 
has  heightened  suspicion  of  the  connection  between  the  plant  and 
increased  cancer  incidents  in  surrounding  communities.  The  State 
Department  of  Public  Health  confirmed  this  increase  in  1986. 

Because  the  report  was  criticized  for  omitting  crucial  data,  a  new 
study  was  promised,  which  was  to  include  more  recent  data,  causal 
factors,  occupational  risks  and  study  of  cancer  incidence  in  commu- 
nities near  nuclear  powerplants  in  New  England.  This  study  should 
be  completed  before  Pilgrim  is  allowed  to  restart. 

Pilgrim's  poor  management  has  been  a  serious  concern  since  the 
plant  was  licensed  in  1972.  Edison's  decision  to  use  known  defective 
fuel  resulted  in  widespread  contamination  of  the  plant  and  contrib- 
uted to  their  inability  to  control  iodine  releases  during  the  early 
1970's.  They  subsequently  applied  to  the  NRC  for  a  revision  of  spec- 
ifications to  provide  for,  quote,  "operational  flexibility",  end  quote. 
It  was  granted. 

Following  Edison  study  findings  in  1982,  the  NRC  assigned  spe- 
cial priorities  to  monitoring  the  management  of  Pilgrim.  By  1986, 
16,000  hours  of  inspection  time  had  been  spent  at  Pilgrim,  and  a 
third  resident  inspector  assigned.  This  is  50  percent  more  inspec- 
tion hours  than  spent  in  similar  plants  in  the  northeast,  a  peculiar 
commitment  of  resources  to  oversee  a  plant  that  the  NRC  keeps  as- 
suring us  has  always  been  operated  in  a  safe  manner. 

Following  Edison — oh,  excuse  me.  Still  the  problems  persist. 
Since  1984,  about  100  mishaps  have  occurred  at  Pilgrim;  12  acci- 
dents have  occurred  since  1982,  causing  Edison  to  notify  state  offi- 
cials and  police.  Despite  the  objections  of  State  Secretary  of  Public 
Safety,  22  legislators  and  concerned  residents,  Edison  refueled  the 
reactor  with  no  evacuation  plan  in  place  and  without  notifying  the 
appropriate  authorities. 

They  also  commenced  the  refueling  on  the  very  day  they  assured 
the  press  that  the  procedure  would  be  done  a  week  later.  When 
questioned  about  the  contradiction,  the  NRC  responded,  quote,  "if 


39 

the  utility  lied  to  the  public  or  to  reporters,  there  is  no  authority 
under  the  Atomic  Energy  Act  for  the  NRC  to  do  anything  about  it. 
There  is  no  law  that  says  they  have  to  tell  reporters  the  truth," 
end  quote. 

In  November  of  1987,  a  series  of  spills  and  leaks  resulted  in  the 
contamination  of  several  workers.  Edison's  vice  president  was  in 
Florida  at  the  time.  There  was  no  NRC  resident  inspector  on  site. 
Plant  spokesmen  originally  denied  any  leaks,  and  then  later  ac- 
knowledged them.  Later  a  single  generator  was  the  only  source  of 
electricity  to  provide  cooling  for  the  loaded  reactor.  If  the  plant 
had  been  operating  and  that  generator  failed,  we  would  have  had 
to  implement  the  evacuation  plan  that  we  do  not  have. 

Something  is  wrong  here.  Senator.  Boston  Edison  has  withheld 
documents  from  the  public  document  room  with  the  permission  of 
the  NRC.  Many  missing  have  been  obtained  through  the  Freedom 
of  Information  Act  and  chronicle  a  history  of  unmonitored  releases 
to  our  environment.  Edison  continues  to  tell  us  that  there  has  been 
no  releases  in  excess  of  technical  specifications.  The  NRC  has  not 
made  any  attempt  to  contradict  the  known  misinformation. 

During  the  last  18  months,  we  have  been  assured  by  the  NRC 
and  the  industry  that  nuclear  power  has  defense  in  depth,  and 
we're  often  reminded  that  there  are  inherent  risks  associated  with 
all  forms  of  energy.  The  risks  we  are  being  asked  to  bear  are  unac- 
ceptable. 

Since  local  and  State  officials  are  powerless  to  resolve  our  dilem- 
ma and  the  NRC  refuses  to  hear  our  requests  for  a  legal  hearing, 
we  appeal  to  your  committee  to  initiate  an  independent,  congres- 
sionally  sponsored  investigation  into  the  health  and  safety  impact 
of  the  operation  of  Pilgrim,  and  further  into  the  conduct  of  the  Nu- 
clear Regulatory  Commission.  Only  a  legal  inquiry  can  provide  the 
truth  about  Pilgrim's  troubled  history.  Such  a  hearing  is  needed  if 
public  confidence  in  our  system  and  in  the  NRC  is  to  be  restored. 
Thank  you,  Senator. 

[The  prepared  statement  of  Ms.  Ott  (with  attachments),  follows:] 


40 


TESTIMONY  OF  MARY  C.  OTT,  CO-CHAIRMAN,  DUXBURY 
CITIZENS  URGING  RESPONSIBLE  ENERGY  (CURE)  BE- 
FORE THE  U.S.  SENATE  COMMITTEE  ON  LABOR  AND 
HUMAN  RESOURCES,  JANUARY  7,  1988. 

Senator  Kennedy,  members  of  the  Senate  committee,  my  name  is  Mary  Ott  and  1  am  the  Co- 
Chairman  of  Duxbury  Citizens  Urging  Responsible  Energy.  We  commend  you  for  calling  this 
important  meeting,  and  are  grateful  for  the  opportunity  to  express  our  deepening  concern 
about  the  health  and  safety  impact  of  the  restart  of  the  Pilgrim  Nuclear  Power  Station  and  fur- 
ther, at  the  failure  of  the  U.S.  Nuclear  Regulatory  Commission  (NRC)  to  perform  its  sanction- 
ed duty  to  regulate  this  utility. 

Our  concerns  encompass  Pilgrim's  flawed  GE  Mark  I  containment;  its  poor  management 
history;  the  lack  of  evacuation  plans  for  area  residents;  the  threat  posed  by  the  continued  stock- 
piling of  tons  of  nuclear  waste  on  site;  the  alarming  increase  of  cancer  in  the  five  towns  down- 
wind; and  finally  the  credibility  of  the  Boston  Edison  Company  and  its  regulator,  the  NRC. 

Although  a  conclusive  link  has  not  been  found.  Pilgrim's  history  has  heightened  suspicion  of 
the  connection  between  the  plant  and  increased  cancer  incidence  in  surrounding  communities. 

The  State  Department  of  Public  Health  confirmed  this  increase  in  1986.  Because  the  report 
was  criticized  for  omitting  crucial  data,  a  new  study  was  promised  which  is  to  include  more  re- 
cent data,  causal  factors,  occupational  risks,  and  a  study  of  cancer  incidence  in  communities 
near  nuclear  power  plants  in  New  England.  This  study  should  be  completed  before  Pilgrim  is 
allowed  to  restart. 

Pilgrim's  poor  management  has  been  a  serious  concern  since  the  plant  was  licensed  in  1972. 
Edison's  decision  to  use  known  defective  fuel  resulted  in  widespread  contamination  of  the 
plant,  and  contributed  to  their  inability  to  control  Iodine  releases  during  the  early  '70's.  They 
subsequently  applied  to  the  NRC  for  a  revision  of  technical  specifications*  to  provide  for 
"operational  flexibility."  It  was  granted. 

Following  Edison's  precedent-setting  $550,000  fine  in  1982,  the  NRC  assigned  special  priori- 
ty to  monitoring  the  management  of  Pilgrim.  By  1986,  16,000  hours  of  inspection  time  had 
been  spent  at  Pilgrim  and  a  third  resident  inspector  assigned.  This  is  SO'yo  more  inspection  hours 
than  spent  at  similar  plants  in  the  Northeast.  A  peculiar  commitment  of  resources  to  oversee  a 
plant  that  the  NRC  keeps  assuring  us  has  always  operated  in  a  safe  manner. 

Still,  the  problems  persist.  Since  1984,  about  /oo  mishaps  have  occurred  at  Pilgrim.* 
Twelve  accidents  have  occurred  since  1982,  causing  Edison  to  notify  state  officials  and  police. 

Despite  the  objections  of  the  State  Secretary  of  Public  Safety,  22  legislators  and  concerned 
residents,  Edison  refueled  the  reactor  with  no  evacuation  plan  in  place  and  without  notifying 
appropriate  authorities.  They  also  commenced  the  refueling  on  the  very  day  that  they  assured 
the  press  that  the  procedure  would  be  done  a  week  later.  When  questioned  about  the  contradic- 
tion, the  NRC  responded,  "If  the  utility  lies  to  the  public  or  to  reporters,  there  is  no  authority 
under  the  Atomic  Energy  Act  for  the  NRC  to  do  anything  about  it.  There  is  no  law  that  says 
they  have  to  tell  reporters  the  truth."* 

In  November  a  series  of  spills  and  leaks  resulted  in  the  contamination  of  several  workers. 
Edison's  Vice  President  was  in  Florida  at  the  time.  There  was  no  NRC  resident  inspector  on 
site.  Plant  spokesmen  originally  denied  any  leaks,  then  later  acknowledged  them. 

•BECO  letter  to  NRC  dated  May  22.  1975 

•South  Look,  Karl  Abraham,  Region  I,  NRC,  Oct.  6-8.  1987 


41 


The  plant  experienced  a  complete  lost  of  offsite  power  for  21  hours.  A  single  generator  was 
the  only  source  of  electricity  to  provide  cooling  to  the  loaded  reactor.  If  the  plant  had  been 
operating,  and  that  generator  failed,  we  would  have  had  to  implement  the  evacuation  plan  thai 
we  do  not  have. 

Something  is  wrong  here.  Boston  Edison  has  withheld  documents  from  the  public  document 
room  with  the  permission  of  the  NRC.  Many  missing  have  been  obtained  through  the  Freedom 
of  Information  Act  and  chronicle  a  history  of  unmonitored  releases  to  our  environment. 
Edison  continues  to  tell  us  that  there  have  been  no  releases  in  excess  of  technical  specifications. 
The  NRC  has  not  made  any  attempt  to  contradict  the  known  misinformation. 

During  the  last  18  months,  we  have  been  assured  by  the  NRC  and  the  industry  that  nuclear 
power  has  "defense  in  depth,"  and  are  often  reminded  that  there  are  inherent  risks  associated 
with  all  forms  of  energy.  The  risk  we  are  being  asked  to  bear  is  unacceptable. 

Since  local  and  state  officials  are  powerless  to  resolve  our  dilemma,  and  the  NRC  refuses  to 
grant  our  request  for  a  legal  hearing,  we  appeal  to  your  committee  to  initiate  an  independent, 
Congressionally-sponsored  investigation  into  the  health  and  safety  impact  of  the  operation  of 
Pilgrim;  and  further,    into  the  conduct  of  the  Nuclear  Regulatory  Commission. 

Only  a  legal  inquiry  can  provide  the  truth  about  Pilgrim's  troubled  history.  Such  a  hearing  is 
needed  if  public  confidence  in  our  system,  and  the  NRC,  is  to  be  restored. 

Thank  you. 


Postscript:  CURE  Co-Chairman,  Dr.  Donald  M.  Muirhead  Jr.  and  his  associate  Dr.  Belton 
Burrows  have  submitted  additional  written  testimony  regarding  the  health  effects  of  radiation. 


42 


/.;(  CA 


y^r^.5-^.2/j.-   y^J't/ 


dOBTON    CotsoN    Company 

r««Cu»"*f    0'r-Ct« 

aOO    BovLflTOH    S*aCCT 
aoaTOM.    H^cVACMuirrra    02I99 


•^0 


Qt%. 


Director 

Division  of  Reactor  LI'  —<"!•. 
Office  of  Nuclear  Ren  '"r   Regulation 
U.S.  Nuclear  RoRulat     Coimlssloi 
U.ishlnpton,  D.C.   20555 


Mjy  22,  1975     ,^     ',h 


Di.,  et  No.  50-293 
License  DPR-35 


Subject:   Proposed  Revision  to  Airborne  Effluents 

Technical  Specification  for  PilRrlni  Unit  CI 

Dr.Tr  Sir: 


iipcr.itlon  of  PilRrin  N'uclear  Power- Scat  ion  In  accordance  with  the  present 
Technical  Specifications  has  revealed  that  section  3.8. B. 2  of  the  speclflca- 
ilons  should  be  revised  to  more  accurately  describe  the  Intent  of  the 
specification  ind  provide  operational  flexibility.   Accordingly,  Bi  ton 
Ccison  Conpany  hereby  requests  that  the  attached  proposed  revlslor   to 
r^nlinic.il  Specif Ic.nlon  pages  179.  179A,  179B,  191A  and  191B  be    lued  Co 
provide  the  necessary  r  larlf  Icaclor.  and  definition. 

This  submittal  has  been  approved  by  the  Onslte  Review  Committee  but  has  not 

been  reviewed  by  the  Nuclear  Safecy— Review  tnd  Audit  Conmlrtee  (NSRAC). 

SSRAC  review  is  underway  and  will  be  compleced  during  the  week  bep.lnnlng 
May  27,  1975. 

This  proposed  Technical  Specification  muse  be  considered  Cemporary  since  It 
does  not  reflect  the  requirements  contained  In  Che  new  Appendix  I  Co  10  CFR  50 
Issued  by  the  Connlsslon  on  April  30,  1975  (and  published  In  Che  Federal 
Reglscer,  Voluoe  40,  No.  87,  May  5,  1975).   Boston  Edison  will  propose  further 
revisions  to  the  Technical  Specifications  on  effluent  releases  In  accordance 
with  the  new  Appendix  I  not  later  than  June  4,  1976. 


Conronucilth  of  Massachusetts) 
County  of  Suffolk  ; 


VeiO  crul; 


your 


w^suR 


rhen  personally  appeared  before  me  Francis  M.  Staszesky,  who,  being  duly  sworn, 
did  state  Chat  he  Is  Executive  Vice  President  of  Boscon  Edison  Company,  Che 
applicant  herein,  and  that  he  is  duly  authorized  to  execute  and  file  Che 
proposed  Technical  Specification  revisions  described  herein  in  Che  name  and 
on  behalf  of  Boston  Edison  Company  and  Chac  the  staternentfl  In  nald  proposed 
revisions  are  true  to  the  best  of  his  knowledge  and  belief.  ^      .yY 


My  Ccmimiaslon  expires: 


Notary  Publ'c 


DMC  n  SI.-vii  r-v 


y 


43 


59 


TABLE  2 


LER  SYNOPSIS  (11/01/85  -  01/31/87) 
PILGRIM  NUCLEAR  POWER  STATION 


LER 
NUMBER 

EVENT 
DATE 

CAUSE 
CODE 

85-028-00 

10/10/85 

X 

85-029-00 

10/18/85 

X 

85-030-00 

10/30/85 

X 

85-031-00 

10/29/85 

X 

85-032-00 

11/25/85 

B 

85-033-00 

11/27/85 

X 

85-034-00 

12/31/85 

B 

86-001-00 

01/06/86 

A 

86-002-00 

01/16/86 

X 

86-003-00 

02/11/86 

E 

86-004-00 

02/20/86 

X 

86-005-00 

03/07/86 

B 

86-006-00 

03/16/86 

B 

SUMMARY  DESCRIPTION 

INADEQUATE  SURVEILLANCE  PROCEDURE 
FOR  STANDBY  GAS  TREATMENT  SYSTEM 

HIGH  PRESSURE  COOLANT  INJECTION 
SYSTEM  AND  ANTICIPATED  TRANSIENT 
WITHOUT  SCRAM  SYSTEM  INVERTERS 
INOPERABLE 

INADEQUATE  RECIRCULATION  PUMP 
START  PROCEDURE 

FAILURE  TO  MEET  MINIMUM  SHIFT 
CREW  COMPOSITION 

MAIN  STEAM  LINE  HIGH  FLOW  SWITCH 
SETPOINT  DRIFT 

MAIN  STACK  AND  RBV  MISSED 
SURVEILLANCE  TEST 

TECHNICAL  SPECIFICATION  REQUIRED 
FIRE  DAMPERS  FOUND  DEGRADED 

UNPLANNED  REACTOR  SCRAM  ON  LOW 
WATER  LEVEL  DUE  TO  OPERATOR  ERROR 

REACTOR  SCRAM  DUE  TO  PRESSURE 
SWITCH  SENSITIVITY 

480  V  SAFETY  BUS  INADVERTENTLY 
DEENERGIZED  DURING  MAINTENANCE 

STANDBY  LIQUID  CONTROL  SYSTEM 
DECLARED  INOPERABLE  WHEN      ^ 
SQUIB  VALVES  NOT  TESTED  INSITU 

HEAD  SPRAY  PIPING  LEAK  IN  TORUS 
ROOM 

WELD  LEAK  ON  REACTOR  WATER  LEVEL 
INSTRUMENT  LINE 


44 


60 


LER 

NUMBER 

EVENT 
DATE 

CAUSE 
CODE 

86-007-00 

03/22/86 

X 

86-008-00    . 

04/04/86 

m 

X 

86-009-00 

04/11/86 

X 

86-010-00 

04/15/86 

X 

86-011-00 

04/19/86 

X 

86-012-00 

05/16/86 

X 

86-013-00 

05/30/86 

B 

86-014-00 

06/10/86 

X 

86-015-00 

06/13/86 

X 

86-016-00 

06/21/86 

E 

86-017-00 

07/01/86 

X 

86-018-00 

06/29/86 

X 

86-019-00 

07/15/86 

X 

86-020-00 

08/20/86 

D 

SUMMARY  DESCRIPTION 

MAIN  STEAM  LINE  ISOLATION  WHILE 
REACTOR  SHUTDOWN 

REACTOR  SCRAM  AND  MAIN  STEAM 
ISOLATION  VALVE  (MSIV)  RESET 
PROBLEMS 

IN  SERIES  PRIMARY  CONTAINMENT 
ISOLATION  VALVES  M0-1001-28B 
AND  29B  INDICATING  LEAKAGE  PAST 
SEATS 

MAIN  STEAM  LINE  ISOLATION  WHILE 
REACTOR  SHUTDOWN 

LEAKAGE  PAST  MSIV'S   IN  EXCESS 
OF  LLRT  CRITERIA 

INSUFFICIENT  ONCE/CYCLE  HPCI 
SURVEILLANCE  PROCEDURE 

USE  OF  NON-SEISMIC  GENERAL 
ELECTRIC  TYPE  CFO  RELAYS 

INSUFFICIENT  ONCE/CYCLE  RCIC 
SURVEILUNCE  PROCEDURE 

PRIMARY  CONTAINMENT  LOCAL  LEAK 
RATE  TESTS  OVERDUE 

BUS  A5,   BUS  A6  AND  STARTUP 
TRANSFORMER  DEGRADED  VOLTAGE 
RELAY  CALIBRATIONS  OVERDUE 

CONTAINMENT  ISOLATION  VALVE 
LOCAL  LEAK  RATE  TEST  FAILURES 

GENERAL  ELECTRIC  AKF  FIELD 
BREAKER  FAILED  TO  TRIP 
AUTOMATICALLY 

INSUFFICIENT  MONTHLY  ATWS 
SURVEILLANCE  PROCEDURE 

UNIDENTIFIED  FIRE  BARRIER  WALLS 
AND  PENETRATIONS 


45 


61 


LER         EVENT        CAUSE 

NUMBER       DATE         CODE         SUMMARY  DESCRIPTION 

86-021-00     08/27/86       B      STANDBY  GAS  TREATMENT  SYSTEM  /^ 

DELUGE  SYSTEM  SINGLE  FAILURE  ^ 
MODE 

E      MISSED  TECHNICAL  SPECIFICATION 
SOURCE  LEAK  CHECK  SURVEILLANCE 

A      MISSED  FIRE  WATCH  AND  FIRE 
WATCH  PATROLS 

X      NON  FIRE  RESISTANT  COATED 
STRUCTURAL  STEEL 

B      MISALIGNMENT  OF  THE  FIRE 
SUPPRESSION  WATER  SYSTEM 

D      FAILURE  TO  PERFORM  RADIO- 
ACTIVE MATERIAL  SURVEILLANCE    /^ 
TEST  OF  STANDBY  GAS  TREATMENT 
SYSTEM  AND  LIQUID  RAD.  EFFLUENT 
MONITOR 

C      LOSS  OF  OFFSITE  POWER  DUE  TO 
SEVERE  WINTER  STORM 

86-028-00     12/23/86       X      FAILURE  TO  RECOGNIZE  THE  EFFECTS 

OF  ELECTRICAL  ISOLATION  RESULTING 
IN  ESF  ACTUATION 

86-029-00     12/23/86       X      LOSS  OF  OFFSITE  POWER  WHILE  WASHING 

SALT  FROM  YARD  INSULATORS 


86-022-00     08/29/86 


86-023-00     09/12/86 


86-024-00     10/07/86 


86-025-00     11/11/86 


86-026-00     10/29/86 


86-027-00     11/19/86 


NOTE: 

There  is  no  published  synopsis  of  Licensee  Event  Reports 
for  1987  at  this  time.  Per  the  Librarian,  Grace  Karbot, 
in  the  Plymouth  Public  Document  Room,  19  such  events 
did  occur  in  1987. 


1984 

20 

1985 

34 

1986 

29 

1987 

19 

TOTAL 


102 


46 


a. 


00 

x> 
o 


o 

CO 


P  3  a  "a  P  .•-]  o.  o 

"  8-  *  -5  |i5  ■<,     ^ 
9     c  °  V  °  a  b  !^ 

°  «  *  ..  o  S      n 


< 

Tuu.a 


«  ^   <5  oo  rt   ^  r> 

3  3  g  *  5  I 
it    2g 


^3-0 


5.5 


p    O  ^  ' 

£-5  u>S 

*i      .  c 

»  i  u  ^ 

.  a 

3  > 

J  O 


'9 


47 


Page  1 


QUESTIONS  FOR  INCLUSION  IN  CONGRESSIONAL  RECORD  OF  JAN. 
7,  1988  hearing  on  the  restart  of  the  Pilgrim  Nuclear 
Power  Plant 

submitted  by  Citizens  Urging  Responsible  Energy 

HEALTH  ISSUE: 

1.  What  is  the  reason  for  the  State's  failure  to  investigate 
Boston  Edison's  alleged  dumping  of  radioactive  materials 

on  their  property^in  Plymouth?  (promised  in  Aug.,  1987) 

2.  Boston  Edison  has  admitted  to  dumping  radioactive 
.material  at  the  Plymouth  town  dump  site.   Do  state  and 
|federal  regulations  permit  such  action?   Are  not  Plymouth 

■residents  exposed  to  radiation  when  using  the  dump? 

3.  Massachusetts  is  the  nation's  fifth  largest  producer 
of  low-level  nuclear  waste.  (100,000  cubic  feet)   What 
portion  of  that  waste  is  generated  by  Pilgrim?   How  does 
that  compare  with  similar  size  plants  of  the  same  design? 

4.  After  the  radioactive  leaks  in  Nov.,  1987,  CURE  requested 
that  air  sampling  and  soil  testing  be  done  by  the  Mass.  Dept. 
of  Public  Health.   The  state  agreed  to  the  undertaking,  but  did 
not  do  it.   Who  decided  that  this  was  not  necessary? 

5.  Almost  2  years  have  elapsed  since  the  State  promised  to 
redo  and  upgrade  the  health  study  of  high  cancer  incidence 
in  the  5  towns  downwind  of  Pilgrim.   What  is  the  current 
status  of  the  study?   Does  the  state  feel  that  the  issue  of  a 
possible  conclusive  link  between  adverse  health  effects  and 
Pilgrim  should  be  resolved  before  the  plant's  restart? 

6.  Boston  Edison  undertook  a  study  of  their  employees'  and 
former  employees'  health  status.   Is  this  study  completed? 
Does  it  have  preliminary  findings?   Will  it  be  shared  with 
the  MDPH? 

7.  What  were  the  NRC  and  state  radiation  monitoring  readings 
in  June,  1982  when  highly  radioactive  resin  was  blown  out 

a  100  ft.  duct  and  deposited  on  roof  tops  and  paved  areas  at 

Pilgrim?  (all  readings:  onsite,  stack,  offsite) 

Was  data  retrieved  from  dosimeters  at  all  locations? 

8.  CURE  reported  allegations  to  the  NRC  last  summer  regarding 
the  removal  of  shrubbery  onsite  at  Pilgrim  which  was  said  to  be 
radioactive.   The  NRC  said  that  the  licensee  stated  the  bushes 
were  removed  for  security  reasons.   They  later  admitted  that 
there  was  some  amount  of  radioactivity  and  would  investigate 
the  matter.   How  do  bushes  at  Pilgrim  become  radioactive? 
Where  were  they  taken?   Were  appropriate  surveys  conducted? 


48 


QUESTIONS  ON  HEALTH  ISSUE,  CONT'D  Page  2 


9.  NRC:   Please  interpret,  based  on  the  Sandla  report, 
the  expected  number  of  deaths  and  casualities,  long  and 
short-term,  which  would  result  from  an  accident  at  Pilgrim, 
(in  laymen's  terms) 

10.  NRC:   Can  you  provide  figures  on  the  increase  of 
background  radiation  over  the  last  15  years?  (in  laymen's  terms) 
What  percentage  of  the  increase  is  attributed  to  man-made 
radioactive  nuclfdes  (i.e.  cesium  137,  I  131,  strontium  90, 
etc.)?   Are  figures  available  locally  and  nationally? 

What  are  the  present  figures  for  natural  background  radiation 
(i.e.  solar  rays,  etc.)? 

11.  NRC:   Has  Boston  Edison  ever  exceeded  technical  speci- 
fications on  radioactive  releases  from  Pilgrim? 

On  what  dates,  and  in  what  amounts  over  specification? 

Are  there  fines  or  violations  associated  with  such  releases? 


49 


Page  3 


QUESTIONS  FOR  INCLUSION  IN  CONGRESSIONAL  RECORD  OF  JAN. 
7,  1988  hearing  on  the  restart  of  the  Pilgrim  Nuclear 
Power  Plant 

submitted  by  Citizens  Urging  Responsible  Energy 

FIRE  PROTECTION: 

1.  Is  BECO  now  in  full  compliance  with  Appendix  R  require- 
ments in  fire  protection?   Have  they  applied  for  any  waivers? 

2.  Are  all  barriers,  fire  doors  and  penetration  seals 
repaired  and  capable  of  passing  required  testing? 

3.  In  Feb.,  1986  72  locations  at  Pilgrim  were  being  observed  by 
fire  watches  because  of  unfinished  maintenance  in  the  area  of  fire 
protection.   How  many  were  being  observed  on  Jan.  1,  1988? 

4.  Is  the  water  pressure  from  the  town  of  Plymouth  adequate 
to  fight  a  fire  on  the  second  floor  of  Pilgrim  Station? 

5.  The  Standby  Gas  Treatment  deluge  system  has  been  reported 
to  be  inoperative  since  1984  because  it  requires  an  outage 

to  test  it.   Has  this  matter  been  resolved  during  the  current 
outage?   If  not,  why  not? 

6.  The  Halon  system  in  the  computer  room  is  reported  to  have 
been  inoperable  since  March,  1985  because  there  is  no  pro- 
cedure to  test  it.   Why  isn't  there  a  procedure?   When  will 
there  be  one? 

7.  What  procedures  are  in  place  to  suppress  a  fire  in  the 
computer  room  since  the  halon  system  in  inoperative? 

8.  The  smoke  detectors  over  the  spent  fuel  pool  have  been 
inaccessible  to  test  since  May,  1984.   BECO  is  said  to   be 
investigating  acquiring  a  compact  scissors  lift  to  test  to 
test  these  and  other  inaccessible  detectors  in  April,  1986. 
Has  it  been  acquired?   Have  they  been  tested  since  that  time? 

9.  BECO  documents  reveal  that  some  outstanding  maintenance 
requests  (mrs)  in  the  area  of  fire  protection  which  were 
established  several  years  ago  have  been  assigned  1987  m.r. 
numbers  giving  the  impression  that  they  represent  newly 
identified  problems.   Please  list  outstanding  mr .  in  this  area, 
and  the  dates  each  m.r.  was  established. 

10.  CURE  received  a  report  that  Pilgrim's  onsite  fire 
brigade  was  activated  to  investigate  the  sound  of  a  small 
explosion  and  the  smell  of  "something  burning"  on  Nov.  12th 
at  the  time  of  the  power  loss.   Evidence  has  been  shown  to 
Department  of  Public  Safety  and  the  Senate  Committee. 

The  NRC  and  BECO  continue  to  deny  these  reports.   What  pro- 
cedures were  used  by  the  NRC  to  investigate  this  allegation? 
Did  onsite  NRC  inspectors  question  employees  who  would  have 
been  assigned  to  the  brigade  at  that  tinie? 


50 

Page  4 


QUESTIONS  FOR  INCLUSION  IN  CONGRESSIONAL  RECORD  OF  JAN. 
7,  1988  hearing  on  the  restart  of  the  Pilgrim  Nuclear 
Power  Plant 

submitted  by  Citizens  Urging  Responsible  Energy 
GENERAL  SAFETY: 

1.  Did  BECO  shut  Pilgrim  down  voluntarily  on  April  11,  1986, 
or  did  the  NRC  shut  them  down? 

2.  Is  the  Confirmatory  Action  Letter  (CAL)  still  in  effect? 

3.  Was  -unusual  event"  the  proper  declaration  for  the  emergency 
at  Pilgrim  which  began  on  April  10,  1986?   NUREG-0654,  page  1-9, 
item  4.  classifies  a  Main  Steam  Isolation  valve  malfunction 
causing  leakage  as  an  "alert  declaration." 

4.  Was  the  emergency  in  April  caused  by  a  recurring  GE  design 
problem  with  the  Main  Steam  Isolation  Valves? 

5.  On  Oct.  29,  1987  at  the  Duxbury  forum,  BECO  claimed  to 
have  resolved  the  main  steam  isolation  valve  problems  which 
have  been  identified  by  GE  in  the  Reed  report  as  unresolved 
generic  issues.   Has  this  resolution  been  shared  with  the  NRC  or  GE. 
Is  there  documentation  of  this  resolution  in  published  form? 

6  On  April  4,  1986,  the  Residual  Heat  Removal  (RHR)  A  Loop  was 
shut  down  for  repairs.  Was  the  RHR  A  Loop  repaired  and  operable 
on  April  10,  1986? 

7.  We  have  noted  no  emergency  event  declarations  since  the 
shutdown  in  April, 1986.   The  NRC  says  that  declaration  require- 
ments do  not  apply  to  plants  that  are  not  operating.   ^hy  then 
were  three  inspectors  dispatched  to  New  Hampshire  and  Seabrook 
cited  for  a  violation  in  procedure  for  not  notifying  the  state 
of  Massachusetts  within  15  minutes  of  the  declaration  of  an 
"unusual  event"? 

8.  How  many  scrams  (manual  and  automatic)  have  occurred  at 
Pilgrim  since  it  began  operation  in  1972?   Do  scrams  con- 
tribute  to  core  embrittlement?  What  is  the  industry  average? 

9.  What  tests  have  been  performed  to  assess  any  potential 
weakening  or  embrittlement  of  the  Pilgrim  reactor?   Who  did 
them?   What  were  the  results?   When  were  they  done? 

10.  BECO  has  spent  30  million  dollars  on  enhancements  to 
their  GE  Mark  I  containment.   Ten  million  of  that  amount  is 
said  to  have  been  spent  on  a  risk  assessment  study.   Does  the 
NRC  have  a  copy  of  this  document?   Will  they  share  it  with 
state  officials? 


51 


QUESTIONS  ON  GENERAL  SAFETY,  CONT'  Page  5 

11.  How  many  "substantial  safety  hazard"  reports  (or  their 
equivalent)  have  been  generated  by  Pilgrim  since  1972? 
Please  define  report  and  list  the  dates  and  reasons  for  such. 
How  does  Pilgrim's  average  compare  to  similar  size  plants  of 
the  same  design? 

12.  How  many  violations  of  NRC  requirements  have  taken  place 
at  Pilgrim  since  1972?  How  does  the  total  compare  to  similar 
size  plants  of  the  same  design? 

13.  On  August  15,  1986,  BECO  notified  the  NRC  that  contrary 
to  technical  specification  requirements,  monitoring  of  the 
primary  containment  inerting  system  makeup  flow  rates  had 
not  been  conducted. (said  to  detect  any  large  increase  in 
containment  leakage)   They  further  stated  that  instrumentation 
used  to  perform  such  monitoring  had  been  out  of  service  since 
January,  1985.   Did  the  NRC  cite  or  fine  BECO  for  this  vio- 
lation of  procedure?   Is  this  instrumentation  now  functional? 

14.  Is  the  Standby  Gas  Treatment  System  activated  by  a  power  loss? 

15.  If  direct  torus  venting  were  to  be  used,  what  is  the 
range  of  dose  rates  at  the  exclusion  zone  boundary  in  the  event 
of  venting?   At  what  pressure  would  venting  take  place? 

16.  If  Pilgrim  had  been  operating  on  Nov.  12,  1987,  and  the 
single  operating  generator  had  failed,  did  the  potential 
exist  for  a  core-melt  accident  sequence?  (please  answer 

yes  or  no) 

In  November,  1987,- 

17.  During  the  power  loss  CURE  received  a  report  that  two 
pumper  trucks  were  called  onsite  at  Pilgrim  to  remove 
excess  water  from  drains.   The  volume  of  water  was  said  to  be 
be  such  that  it  posed  back  up  problems  in  the  plant  which 
would  activate  automatic  sump  pumps;  thereby  drawing  ad- 
ditional electricity  from  the  single  operating  generator. 

If  the  system  had  not  been  pumped  out  before  the  pumps 
engaged,  would  an  emergency  evacuation  have  occurred? 
Was  the  NRC  informed  of  this  incident?   Was  the  waste  water 
contaminated?   Was  it  tested?   Where  was  it  taken? 


52 


Page 


QUESTIONS  FOR  INCLUSION  IN  CONGRESSIONAL  RECORD  OF  JAN. 
7,  1988  hearing  on  the  restart  of  the  Pilgrim  Nuclear 
Power  Plant 

submitted  by  Citizens  Urging  Responsible  Energy 

EMERGENCY  PLANNING:   NRC,  FEMA  and  State  Officials 

1.  What  agency  is  liable  for  damages  incurred  as  a  result  of 
an  improperly  implemented  evacuation  plan? 

2.  If  a  radioactive  plume  can  travel  10  miles  per  hour,  how 
can  people  evacuate  to  a  proper  shelter  under  adverse  weather 
conditions? 

3.  Is  it  true  that  the  planning  for  the  health  and  safety  of 
residents  in  the  EPZ  is  not  based  on  a  worst  case  scenario  event? 

4.  Does  Duxbury  need  a  3rd  reception  center  to  decontaminate 
evacuees? 

5.  BECO'S  KLD  time  estimate  study  indicates  that  during  a 
major  snowstorm,  50%  of  all  driveways  will  be  plowed  within 
30  minutes.   Vfhat  is  the  basis  for  that  judgement? 

6.  NRC:   define  explicitly  the  role  FEMA'S  judgement  will 
play  in  determining  the  "adequacy"  they  claim  will  be  required 

in  emergency  planning  before  they  will  grant  permission  for  restart. 

7.  FEMA  announced  withdrawal  of  approval  of  Pilgrim's 
evacuation  plan  on  August  6,  1987.   The  NRC  has  now  exceeded  the 
120-day  period  to  make  a  decision  regarding  FEMA'S  negative 
findings.   When  will  that  decision  be  made? 

8.  Why  has  BECO'S  Bus  Shelter  Survey  not  been  made  available 
to  communities  in  the  EPZ? 

9.  FEMA  declined  to  participate  in  a  forum  sponsored  by  the 
the  Duxbury  Board  of  Selectmen  on  Oct.  29,  1987  because  of  a 
prior  commitment  and  said  therft^ staff ' s  time  was  consumed 

with  the  Seabrook  issue.   Does  FEMA  give  preference  to  licensing 
over  safety  issues? 

10.  What  provisions  have  been  made  to  segregate  the  prisoners 
at  the  Plymouth  County  House  of  Correction  from  other  people 
evacuating  in  the  case  of  an  emergency  at  Pilgrim? 

11.  Will  the  NRC  make  a  restart  decision  regarding  evacuation 
planning  on  potential  solutions  proposed  by  BECO,  or  on  completed 
plans  which  have  been  verified  with  letters  of  agreement  and 

approved  by  the  local  communities  and  the  Commonwealth  of 
Massachusetts? 


53 

The  Chairman.  Dr.  Healy. 

Dr.  Healy.  Thank  you,  Mr.  Chairman. 

The  Plymouth  Committee  on  Nuclear  Matters,  formally  consti- 
tuted by  the  Board  of  Selectmen  on  August  19,  1986,  consists  of 
nine  members  of  diverse  backgrounds  and  experience,  with  exper- 
tise in  the  medical  and  legal  fields;  in  business  and  industry,  in- 
cluding the  utilities;  in  physics  and  engineering,  in  planning  and  in 
public  policy. 

The  committee  members  while  differing  sometimes  radically  in 
their  opinions  have  one  common  passion,  that  of  the  discovery  of 
what  is  fact.  We  have  done  our  best  to  put  aside  our  individual 
biases  in  order  to  listen  to  knowledgeable  others. 

Thus  far,  the  committee  has  issued  two  reports.  The  first  on  the 
Plymouth  Radiological  Emergency  Response  Plan;  the  second  on 
Environmental  Radiation  Monitoring.  In  the  first  report,  we  said 
the  following  in  March  1987: 

There  are  deficiencies  in  the  Plymouth  Radiological  Emergency 
Response  Plan  which  are  serious  enough  in  the  committee's  judg- 
ment to  preclude  reasonable  assurance  that  adequate  protective 
measures  can  and  will  be  taken  by  the  town  and  the  state  in  the 
event  of  a  radiological  emergency. 

Hence,  the  committee  made  the  following  recommendations: 

1.  That  there  be  a  comprehensive  revision  of  the  Plymouth  Radi- 
ological Emergency  Response  Plan.  This  task  is  incomplete. 

2.  That  there  be  an  appointment  made  of  a  full-time  civil  defense 
director.  That  individual  will  begin  on  January  11,  next  Monday. 

3.  Development  of  funds  for  emergency  preparedness  from  Feder- 
al, State  and  utility  sources.  The  only  funds  forthcoming  have  been 
from  Boston  Edison. 

4.  Full  town  participation  in  a  comprehensive  drill  prior  to  Pil- 
grim's coming  back  on-line.  This  has  not  been  done. 

Regarding  the  second  committee  report,  the  Committee  on  Nucle- 
ar Matters  is  strongly  concerned  with  what  it  considers  to  be  the 
insufficient  number  of  monitoring  stations,  the  minimal  and  per- 
functory involvement  of  the  State  in  the  monitory  process  and  the 
complete  lack  of  an  oversight  monitoring  system. 

All  of  the  many  reports  reviewed  by  the  Committee  on  Nuclear 
Matters  indicate  to  its  members  that  the  Pilgrim  nuclear  power 
plant  does  have  a  continuing  environmental  impact.  In  all  the  ma- 
terials reviewed,  however,  Edison,  NRC  and  the  Commonwealth 
hold  that  offsite  releases  from  the  plant,  as  indicated  by  current 
monitoring,  have  not  exceeded  technical  specifications. 

Boston  Edison  Co.,  the  NRC  and  the  Commonwealth  then  draw 
the  conclusion  that  there  has  been  no  measurable  impact  upon  the 
citizenry.  They  further  claim  that  even  if  there  had  been  any 
impact,  it  would  have  been  minimal  and  far  less  than  the  effects  of 
previous  worldwide  weapons  testing  or  of  the  Chernobyl  accident. 

The  Committee  on  Nuclear  Matters  takes  little  comfort  in  the 
above  comparisons.  Any  environmental  impact  is  our  concern  and 
needs  to  be  examined.  Let  us  not  forget  that  the  impact  of  such  ef- 
fects is  cumulative.  The  committee  questions  the  adequacy  of  cur- 
rent monitoring  around  Pilgrim  I,  even  though  it  is  more  extensive 
than  that  at  some  other  nuclear  plants. 


54 

Hence,  the  committee  recommends  increased  monitoring,  higher 
quality  monitoring,  proper  timing  of  monitoring  to  reveal  effects  of 
specific  plant  incidences  which  involve  radioactive  releases  and 
prompt  reporting  of  the  results.  Accomplishment  of  these  recom- 
mendations is  basic  to  an  investigation  of  the  impact  of  the  station 
upon  citizens'  health;  an  investigation  which  has  yet  to  be  accom- 
plished. 

We  respectfully  request  your  assistance,  Mr.  Chairman,  on  two 
related  matters  which  may  not  be  the  direct  concern  of  your  com- 
mittee. We  request  that  you  exert  your  considerable  leadership  at 
the  national  level  to  help  mitigate  the  unintended,  negative  conse- 
quences of  past  congressional  action  and  inaction  which  have  led  to 
America's  hometown  becoming,  in  fact,  a  high  level  nuclear  dump 
site.  We  beg  you  to  assist  in  relieving  us  of  this  burden.  Only  Con- 
gress can  do  it,  not  the  utilities  and  not  Boston  Edison. 

We  ask  that  you  monitor  closely  the  progress  of  the  Department 
of  Energy's  work  at  the  Yucca  Mountain  drilling  site  in  Nevada  to 
insure  that  the  nation  will  obtain  as  soon  as  possible  a  long,  over- 
due, permanent  repository  for  high  level  nuclear  waste. 

We  also  respectfully  suggest  that  you  help  to  initiate  a  congres- 
sional review  of  the  role  and  the  performance  of  the  Nuclear  Regu- 
latory Commission,  and  reasserting  of  congressional  authority  rela- 
tive to  the  nuclear  industry.  It  is  needed.  We  request  that  you  in- 
troduce corrective  legislation  which  will  ensure  congressional  au- 
thority and  responsibility. 

Thank  you  very  much  for  this  opportunity,  Mr.  Chairman.  It  is 
deeply  appreciated.  I  shall  be  happy  to  answer  any  questions  inso- 
far as  I  am  able. 

[The  prepared  statement  of  Dr.  Healy  (with  attachments)  fol- 
lows:] 


55 


TESTIMONY  BEFORE  THE  LABOR  AND  HUMAN  RESOURCES  COMMITTEE 

OF  THE  UNITED  STATES  SENATE 

(Senator  Edward  M.  Kennedy,  Committee  Chairman) 

By  Dr.  Grace  M.  Healy,  Chairman 

COMMITTEE  ON  NUCLEAR  MATTERS 

TOWN  OF  PLYMOUTH,  MASSACHUSETTS 

Thursday,  January  7,  1988 

The  Plymouth  Committee  on  Nuclear  Matters,  formally  constituted  by  the 
Board  of  Selectmen  on  August  19,  1986,  consists  of  nine  members  of  diverse 
backgrounds  and  experience  with  expertise  in  the  medical  and  legal  fields,  in 
business  and  industry  including  the  utilities,  in  physics  and  engineering,  in 
planning,  and  in  public  policy. 

The  Committee  members,  while  differing  sometimes  radically  in  their 
opinions,  have  one  common  passion  -  that  of  the  discovery  of  what  is  fact . 
We  have  done  our  best  to  put  aside  our  individual  biases  in  order  to  listen 
to  knowledgeable  others.   We  have  researched  facts,  gathering  available 
information  from  voluminous  written  materials  and  reports,  from  interviews  of 
relevant  parties  and  from  public  hearings.   We  have  visited  the  plant, 
participated  in  simulated  emergency  and  training  drills,  consulted  with 
technical  experts  and  deliberated  with  one  another  during  lengthy  committee 
meetings  . 

Our  deliberations  have,  at  times,  been  difficult.   In  the  end,  we  have 
managed  to  reach  consensus  on  most  recommendations.   It  is  clear  that  we 
stand  together  in  our  concern  for  the  safety  of  all  residents  of  Plymouth. 

Thus  far  the  Committee  has  issued  two  Reports:  the  first  on  the  Plymouth 
Radiological  Emergency  Response  Plan;  the  second  on  Environmental  Radiation 
Monitoring.   In  the  first  report  we  said  the  following  in  March  1987: 

There  are  deficiencies  in  the  Plymouth  Radiological  Emergency  Response 

Plan  which  are  serious  enough,  in  the  Committee's  judgment,  to  preclude  "... 

reasonable  assurance  that  adequate  protective  measures  can  and  will  be  taken 

(by  the  Town  and  State)  in  the  event  of  a  Radiological  Emergency."  There  is 

reason  to  believe  that  as  things  stand  now,  the  Selectmen  cannot  fulfill 

their  legal  responsibility,  particularly  during  a  Radiological  Emergency, 

"....  to  provide  for  the  health  and  safety  of  persons  and  their  property 
II 

The  Plymouth  Radiological  Emergency  Response  Plan  is  a  "paper"  plan, 
essentially  untested  relative  to  mobilization  of  some  of  the  essential 
personnel.   Hence,  the  Committee  made  the  following  recommendations: 

1.    Comprehensive  revision  of  the  Plymouth  Radiological  Emergency 
Response  Plan. 
This  task  is  not  complete. 


56 


Page  2 

2.  Appointment  of  a  full-time  Civil  Defense  Director,  with  staff  as 
needed,  with  adequate  interim  headquarters,  and  with  long-term 
plans  for  location  in  one  of  the  new  Town  buildings. 

The  Civil  Defense  Director  will  begin  work  on  January  11.  1988. 

3.  Development  of  funds  for  emergency  preparedness  from  federal,  state 
and  utility  sources. 

Only  funds  from  Boston  Edison  are  being  made  available  to  the  Town. 

4.  Full  Town  participation  in  a  comprehensive  drill  prior  to  Pilgrim's 
coming  back  on-line. 

This  has  not  been  done. 

The  Committee  holds  that  the  Plan  must  be  operat ionalized.   Procedures 
must  be  specified  and  tested.   Commitments  of  personnel  and  materials  must  be 
legally  formalized.   Anything  less  is  unacceptable. 

Regarding  the  second  Committee  Report: 

The  Committee  on  Nuclear  Matters,  in  an  attempt  to  understand  the 
monitoring  of  environmental  radiation  associated  with  the  Pilgrim  Nuclear 
Power  Station,  reviewed  documents  provided  by  Boston  Edison  and  interviewed 
knowledgeable  persons,  including  but  not  limited  to  Boston  Edison 
representatives.  Nuclear  Industry  representatives.  Department  of  Public 
Health  representatives  and  State  Officials. 

The  Committee  on  Nuclear  Matters  is  strongly  concerned  with  what  it 
considers  to  be  the  insufficient  number  of  monitoring  stations,  the  minimal 
involvement  of  the  State  in  the  monitoring  process,  and  the  complete  lack  of 
an  "oversight"  monitoring  system. 

All  of  the  Reports  reviewed  by  the  Committee  on  Nuclear  Matters  (1982- 
1987)  indicate  to  its  members  that  the  Pilgrim  Nuclear  Power  Plant  does  have 
a  continuing  environmental  impact.   In  all  of  the  materials  reviewed, 
however,  Boston  Edison  Company,  the  N.R.C.,  and  the  Commonwealth  bold  that 
offsite  releases  from  the  Plant  (as  indicated  by  current  monitoring)  have  not 
exceeded  technical  specifications.   Boston  Edison  Company,  the  N.R.C.,  and 
the  Commonwealth  then  draw  the  conclusion  that  there  has  been  no  measurable 
impact  upon  the  citizenry.   They  further  claim  that  even  if  there  had  been 
any  impact  it  would  have  been  minimal,  and  far  less  than  the  effects  of 
previous  worldwide  weapons  testing  or  of  the  Chernobyl  accident. 

The  Committee  on  Nuclear  Matters  takes  little  comfort  in  the  above 
comparisons.  Any  environmental  impact  is  of  concern  and  needs  to  be  examined 
if  public  health  is  to  be  protected.   Let  us  not  forget  that  the  impast  of 
such  effects  is  cumulative!   The  Committee  questions  the  adequacy  of  current 
monitoring  around  Pilgrim  I,  even  though  it  is  more  extensive  than  that  at 
some  other  nuclear  plants.   Hence,  the  Committee  recommends  increased 
monitoring,  higher  quality  monitoring,  proper  timing  of  monitoring  to  reveal 
effects  of  specific  plant  incidences  which  involve  radioactive  releases,  and 
prompt  reporting  of  the  results.   Accomplishment  of  these  recommendations  is 
basic  to  an  investigation  of  the  impact  of  PNPS  upon  citizens'  health.  .  .  an 
investigation  which  has  yet  to  be  accomplished. 


57 


Page  3 

The  two  Committee  Reports  mentioned  here  are  being  made  available  to 
your  staff,  Mr.  Chairman,  as  will  be  future  reports  and  recommendations  from 
our  Committee. 

We  respectfully  request  your  assistance  on  two  related  matters  which  may 
not  be  the  direct  concern  of  your  Committee.   We  request  that  you  exert  your 
considerable  leadership  at  the  national  level  to  help  mitigate  the  unintended 
negative  consequences  of  past  Congressional  action  and  inaction  which  have 
led  to  America's  Home  Town  becoming,  in  fact  a  high  level  nuclear  dump  site. 
We  beg  you  to  assist  in  relieving  us  of  this  burden.   Only  Congress  can  do 
it,  not  the  utilities  -  not  Boston  Edison. 

We  ask  that  you  monitor  closely  the  progress  of  the  Department  of 
Energy's  work  at  the  Yucca  Mountain  drilling  site  in  Nevada  to  insure  that 
the  nation  will  obtain  as  soon  as  possible  a  permanent  repository  for  high 
level  nuclear  waste. 

We  also  respectfully  suggest  that  you  help  to  initiate  a  Congressional 
review  of  the  role  and  performance  of  the  Nuclear  Regulatory  Commission,  and 
the  reasserting  of  Congressional  authority  relative  to  the  Nuclear  Industry. 
If  it  is  needed,  we  request  that  you  introduce  corrective  legislation  which 
will  ensure  Congressional  authority  and  responsibility. 

Thank  you  very  much  for  this  opportunity,  Mr.  Chairman;  it  is  deeply 
appreciated.   I  shall  be  happy  to  answer  any  of  your  questions  insofar  as  X 
am  able. 


58 


TOWN  OF  PLYMOUTH 

COMMITTEE  ON  NUCLEAR  MATTERS 


REPORT  TO  THE  SELECTMEN 

ON 

THE  PLYMOUTH  RADIOLOGICAL  EMERGENCY  RESPONSE  PLAN 


March,  1987 


MEMBERS : 


59 


THE  COMMITTEE  ON  NUCLEAR  MATTERS 


Grace  M.  Healy,  Chair 
Charles  W.  Adey,  Vice-Chair 
Ann  Waitkus  Arnold 
Theodore  L.  Boeen 
Marie  P.  Fehlow 
Kenneth  T.  Holmes 
Kathleen  M.  Leslie 
Anthony  V.  Lonardo 
John  P •  Rooney 
James  W.  Ryan 
Howard  E.  Shetterly 


SUBCOMMITTEE  MEMBERS: 


Ann  Waitkus  Arnold 
Kenneth  T.  Holmes 


60 


TOWN  OF  PLYMOUTH 

THE  RADIOLOGICAL  EMERGENCY  RESPONSE  PLAN 

INTRODUCTION 

As  one  of  its  tasks,  the  Committee  on  Nuclear  Matters  assumed  respon- 
sibility for  a  review  of  the  Plymouth  Radiological  Emergency  Response  Plan 
(RERP).  The  following  is  the  result  of  research  undertaken  by  the  sub- 
committee, and  of  the  deliberations  of  the  entire  committee. 

In  order  to  determine  Plan  adequacy  and  feasibility,  information  was 
sought  from  many  sources.  Subcommittee  members  reviewed  written  materials: 
other  Emergency  Response  Plans  (ERP);  Federal  Emergency  Management  Agency 
(FEMA)  Regulations;  reports  on  the  adequacy  of  various  RERP's;  testimony  of 
public  interest  groups,  and  one  available  section  of  Secretary  Barry's 
report.  Subcommittee  members  also  contacted,  in  person  and  by  telephone, 
representatives  from:  (1)  Local,  Regional  and  State  Civil  Defense  Offices, 
(2)  FEMA,  (3)  various  Town  Offices;  (4)  State  Office  of  Handicapped  Affairs; 
and  (5)  Boston  Edison. 

SUMMARY  CONCLUSIONS  AND  RECOMMENDATIONS 

There  are  deficiencies  in  the  Plymouth  RERP.  Moreover,  these 
deficiencies  are  serious  enough,  in  the  Committee's  judgment,  to  preclude 
"...  reasonable  assurance  that  adequate  protective  measures  can  and  will  be 
taken  (by  the  Town  and  State)  in  the  event  of  a  Radiological  Emergency." 
There  is  reason  to  believe  that  as  things  stand  now,  the  Selectmen  cannot 
fulfill  their  legal  responsibility,  particularly  during  a  Radiological 
Emergency,  "....  to  provide  for  the  health  and  safety  of  persons  and  their 
property  . . . ." 

The  Plymouth  RERP  is  a  "paper"  plan,  essentially  untested  relative  to 
mobilization  of  some  of  the  essential  personnel.  As  long  as  it  is  untested, 
difficult  questions  can  remain  unanswered  and  difficult  decisions  can  be 
avoided.  This  is  a  situation  unacceptable  to  the  members  of  the  committee. 
Thus,  we  respectfully  urge  Selectmen  to  assign  tasks  and  timelines  to 
appropriate  personnel  and/or  offices  to  ensure  accomplishment  of  the 
following : 

A.  Comprehensive  revision  of  the  Plymouth  RERP. 

1.  Correction  of  outdated  information. 

2.  Elimination  of  specific  deficiencies  noted  below. 

3.  Complete  specification  of  implementation  procedures. 

4.  Specification   of   procedures   for   ongoing   updating   and 
coordination  with  local,  area,  and  state  plans. 

B.  Appointment  of  a  full-time  Civil  Defense  Director,  with  staff  as 
needed,  with  adequate  interim  headquarters,  and  with  long-term  plans  for 
location  in  one  of  the  new  Town  buildings. 

C.  Development  of  funds  for  emergency  preparedness  from  federal,  state 
and  utility  sources.   (Appointment  of  liaison  for  same.) 


61 


D.  Full  Town  participation  in  a  comprehensive  drill  prior  to  Pilgrim's 
coming  back  on-line.  (While  actual  citizen  evacuation  may  not  be  feasible, 
full  participation  must  at  least  include  all  responsible  personnel  being  in- 
£lace  and  carrying  out  assigned  tasks.)  Coordination  of  agencies,  their 
services  and  lines  of  responsibility  -  local,  state,  federal  levels  must  be 
test  ed . 

The  Committee  further  recommends  that  all  deficiencies  be  remedied  and 
all  recommendations  be  implemented  prior  to  reactor  start-up. 

There  was  one  dissenting  opinion  expressed  concerning  the  above.  The 
objection  relates  to  making  total  task  accomplishment  a  condition  for  reactor 
start-up  when  longer  time  may  be  required  for  some  tasks.  The  dissenting 
opinion  does  not  represent  disagreement  on  deficiencies  or  recommendations, 
but  on  timelines.  In  all  cases  there  is  agreement  on  need  and  urgency  for 
act  ion . 


SPECIFIC  DEFICIENCIES  AND  RECOMMENDATIONS 

Following  are  specific  deficiencies  found  by  the  Committee  on  Nuclear 
Matters  and  some  recommended  corrective  measures;  they  have  been  grouped  in 
eight  categories:  (A)  Advance  Information,  (B)  Notification  and  Communication 
Systems,  (C)  Evacuation  Routes,  (D)  Evacuation  Time  Estimates,  (E)  Transport 
of  Dependent  Populations,  (F)  Reception  Centers  and  Public  Shelters,  (G) 
Medical  Facilities,  and  (H)  Radioprotective  Drugs. 

A.   ADVANCE  INFORMATION 
DEFICIENCIES: 

1.  Inadequate  public  information  in  Emergency  Preparedness  Zone  (EPZ). 

2.  Lack   of   multi-lingual   information   (Italian,   Portuguese,   Spanish, 
Japanese) . 

3.  Inadequate  distribution  of  Emergency  Preparedness  Information  (EPI) 

brochures . 

4.  No  information  for  people  without  access  to  transportation. 

5.  No  information  about  staging  areas  (pick-up  points). 

6.  Tourist  and  transient  information  inadequate  or  non-existent. 

7.  No  educational  effort  outside  the  Town  of  Plymouth. 


/ 


62 


ADVANCE  INFORMATION  (Continued) 
RECOMMENDATIONS : 

1.  Implement  a  comprehensive,  ongoing  public  educational  program  through 
new8  ads,  cable  TV  programs,  radio  public  service  announcements,  and 
informational  packets  included  in  utility  bills.  Include  an  outreach 
program  for  non-English  speaking  people  in  these  activities. 

2.  Develop  emergency  information  posters  (multi-lingual),  with  maps 
explaining: 

-  Protective  Actions  -  Location  of  Public  Transportation 

-  Evacuation  Routes  -  Local  Radio  Station  of  EBS 

-  Location  of  Public  Shelters     -  Staging  Area  Locations 

3.  Post  Emergency  Information  Posters  in  public  locations: 

Hotels,  motels,  restaurants,  gas  stations,  phone  booths,  recreation 
facilities,  tourist  sites,  informational  centers,  theaters,  airports, 
bus  stations,  trolley  cars,  and  all  public  buildings. 

4.  Develop  survey  to  identify  special  populations: 

a.  Non-English  speaking  people. 

b.  Transport  dependent  groups: 

-  15%  of  Plymouth  households  have  no  car; 

-  50%  of  households  have  one  car,  but  one  half  of  workers  have  jobs 
outside  of  Plymouth. 

c.  Special  needs  people: 

-  Federal  regulations  require  notification  of  "all  segments  of 
society." 

-  Deaf  and  hard-of-hearing  people  must  be  identified  beforehand  so 
they  can  be  alerted  by  appropriate  means. 

5.  Distribute  updated  pamphlets  semi-annually  to: 

-  General  public  and  all  recommended  locations  in  #3  above. 

-  Multi-lingual  pamphlets  should  be  available  in  the  same  places. 


63 


B.   NOTIFICATION  AND  COMMUNICATION  SYSTEMS 
DEFICIENCIES: 

1.  Siren  System 

a.  The  siren  system  is  not  equipped  to  confirm  that  all  sirens  have 
been  sounded  during  an  exercise.  There  are  no  provisions  for 
determining  which  sirens  are  not  working. 

b.  Present  siren  system  does  not  warn  hearing-impaired  persons.  No 
alternate  plan  exists  to  notify  this  segment  of  the  population. 

2.  Radio  Communications 

a.  Department  of  Public  Works  radio  equipment  used  for  Civil  Defense 
is  unreliable  and  inadequate. 

b.  Present  system  for  notifying  local  officials  is  unreliable. 

c.  Plymouth  County  radio  network  (Sheriff's)  is  inadequate/ 
inefficient . 

RECOMMENDATIONS: 

ALL  PROCEDURES  FOR  NOTIFICATION  OF  AN  ACCIDENT  AT  PILGRIM  I  SHOULD  BE 
REVIEWED. 

1.  Investigate  the  "hard-wire"  system  or  other  alternatives  that  confirm 
siren  activation.  Alert  officials  who  will  dispatch  personnel  to  areas 
with  defective  sirens  to  activate  sirens  manually  and  to  warn  public 
from  vehicles  and  loudspeakers. 

2.  Develop  procedures  to  confirm  activation  of  every  siren.  Specify 
numbers  of  vehicles  and  personnel  required  for  #1  above. 

3.  Test  sirens  weekly  on  the  same  day  and  at  the  same  time. 

4.  Identify  hearing  impaired  people  and  install  telecommunication  devices. 

5.  Provide  closed  captioning  for  the  Emergency  Broadcasting  System. 

6.  Install  tone  alert  radios  in  every  school  bus,  transport  vehicle,  and 
other  vehicle  specially  licensed  to  transport  children,  the  elderly,  and 
handicapped  persons  in  the  Emergency  Preparedness  Zone. 

7.  Upgrade  Plymouth  County  Radio  network  hardware.  Test  the  hardware  on  a 
regular  basis. 


64 


EVACUATION  ROUTES  -  LIMITED  ACCESS  AND  EGRESS 


DEFICIENCIES; 


1.  Proposed  routes  (Routes  3  and  44)  are  completely  inadequate  for 
effective  handling  of  anticipated  volume  of  traffic.  Traffic  is  already 
jammed  due  to  the  heavy  volume  of  tourists  in  the  summer  months,  and 
during  heavy  winter  storms,  or  when  roads  are  under  construction  or 
repair. 

2.  Voluntary  evacuation  (Evacuation  Shadow  Phenomenon)  is  not  taken  into 
account . 

RECOMMENDATIONS : 

The  following  are  not  remedial;  they  simply  address  worsening  of  the 
problem. 

1.  New  development  along  evacuation  routes  should  require  an  impact  study 
by  developers  with  specifications  set  by  appropriate  Town  Offices.  The 
study  should  be  reviewed  by  the  Planning  Committee. 

2.  Prior  to  approval  of  road  construction/repair  (along  evacuation  routes) 
the  appropriate  Town  Office  must  make  an  impact  assessment  and  develop 
alternative  routes. 


D.   EVACUATION  TIME  ESTIMATES 


DEFICIENCIES: 


Present  time  estimates  are  based  on  outdated  information  and  have  major 
f laws . 


Evacuation  Time 
assumptions : 


Estimates   (ETE)   is   based   on   several   questionable 


It  assumes  there  will  be  no  mass  voluntary  evacuation  not  in 

planned  boundaries  (shadow-phenomenon)  as  occurred  at  Three  Mile 

Island,  which  could  cause  major  route  blockage  and  back-ups. 

It  assumes  that  emergency  personnel  will  remain  in  place  and  not 

evacuate  with  their  families. 

It  assumes  that  communities  outside  the  Ten  Mile  EPZ  have  developed 

adequate   plans   to   augment   evacuation   and   sheltering   efforts, 

although  Massachusetts  Civil  Defense  Agency  (MCDA)  states  no  such 

plan  exists. 

It  assumes  the  timely  presence  of  State  Police  and  National  Guard. 


Large   discrepancies   exist   between 
Regulatory  Commission  (HRC)  ETE's. 


Boston   Edison   and   the   Nuclear 


EVACUATION  TIME  ESTIMATES  (Continued) 

4.  Panic  and  traffic  disorder  have  not  been  adequately  considered: 

a.  Blocking  of  cross  streets 

b.  Disregard  of  traffic  signals 

c.  Driving  in  left  hand  lane 

d.  Abandoned  vehicles 

e.  Driver  confusion 

f.  Failure  of  traffic  control 

g.  Accidents 

These  considerations  plus  ineffective  traffic  control  could  result 
in  more  than  a  50%  reduction  in  traffic  flow,  which  would  mean  the 
evacuation  time  could  be  more  than  doubled. 

5.  No  adequate  estimates  for  time  required  to  evacuate  non-car-owning 
people  dependent  on  public  transport. 

6.  Estimates  of  the  number  of  vehicles  at  public  beaches  is  inadequate. 

7.  Estimates  required  by  federal  regulations  are  lacking. 

a.  Separate  times  for  adverse  weather  -  fog,  rain,  flooding,  snow, 
storms . 

b.  Day  versus  night,  workday  versus  weekend,  peak  transient  versus 
non-peak  transient,  and  evacuation  versus  non-evacuation  in 
adjacent  sectors. 

c.  Separate  estimates  for  "special  population  groups"  on  an 
"institution  by  institution"  basis  (e.g.,  schools,  hospitals, 
nursing  homes,  correctional  facilities). 

RECOMMENDATIONS : 

1.  The  new  Boston  Edison  Company  (BECo)  ETE's  must: 

a.  be  based  on  realistic  assumptions, 

b.  include  all  specific  time  estimates  required  by  FEMA, 

c.  take  into  account  mass  voluntary  evacuation  consequences, 

d.  address  previously  stated  shortcomings. 

2.  The  new  £TE  must  be  completed  prior  to  plant  operation. 

3.  Documentation  should  be  provided  by  BECo  to  assure  the  ETE's  provide  a 
workable  means  to  evacuate  all  residents  of  the  EPZ  based  on  a  wide 
range  of  accident  scenarios. 


66 


E.   FLAMS  TO  TRANSPORT  DEPENDENT  POPULATION 

(People  without  access  to  cars,  school  children  and  children  in  day 
care,  hospital  and  nursing  home  residents,  handicapped  persons,  campers, 
persons  in  correctional  institutions.) 

DEFICIENCIES: 

1.  Numbers  of  vehicles  needed  and  sources  for  them  have  not  been  analyzed. 

2.  No  contracts  or  letters  of  agreement  have  been  signed  with  MBTA,  bus 
companies,  drivers,  ambulance  companies,  and  other  entities  providing 
public  transportation  and  personnel  support  for  the  plan. 

3.  There  are  no  particular  plans  for  evacuating  handicapped  people.  This 
segment  of  the  population  has  not  even  been  identified. 

4.  Plans  call  for  individuals  to  make  arrangements  with  local  CD  for 
transportation.  Local  CD  will  then  contact  MCDA  Area  II  for  assistance; 
however,  the  Area  II  plan  does  not  contain  information  on  how  to  procure 
additional  transportation. 

5.  Schools  -  There  are  no  separate  plans  or  procedures  for  each  school  and 
day  care  center.  Bus  companies  and  drivers  have  not  signed  agreements 
to  perform  during  an  evacuation.  The  school  plan  lacks  detailed  pro- 
cedures. Estimated  time  to  mobilize  National  Guard  for  schools  is  three 
hours,  and  Guardsmen  may  not  be  familiar  with  road  network. 

RECOMMENDATIONS: 

1.  Conduct  a  survey  to  determine  transportation  needs  of  all  people 
dependent  on  public  transportation  in  all  sectors  of  EPZ.  Provide 
specific  and  separate  information  for  summer/non-summer,  weekday/weekend 
populations . 

2.  Document  available  resources  and  resource  needs,  such  as  transportation 
contractors,  trained  personnel,  drivers  trained  in  emergency  response 
procedures,  special  care  personnel  and  equipment  for  disabled  persons. 

3.  Obtain  written  agreements  with  transportation  contractors  and  drivers. 

A.  Develop  specific,  adequate  plans  to  evacuate  each  dependent  group,  such 
as  the  population  in  nursing  homes,  hospitals,  schools,  camps, 
residential  homes,  correctional  institutions,  day  care  centers. 

5.  Provide  for  special  needs  population  -  physically  and  mentally 
handicapped  people: 

a.  Provide  notification  in  advance  of  special  evacuation  procedures 
for  disabled  people; 

b.  Plan  for  delivery  of  necessary  services  during  an  emergency  with 
trained  assistance  for  each  handicapped  person  designated 
beforehand ; 

c.  Provide  beepers,  backup  personnel  for  vacation  times,  special 
equipment  and  medications. 

7 


67 


F.   RECEPTION  CENTERS  AND  SHELTERS 
Bridgewater  State  College  and  Taunton  State  Hospital 
DEFICIENCIES: 

1.  There  are  no  clearly  defined  functions  for  the  reception  centers  and 
shelters . 

2.  There  are  no  letters  of  agreement,  or  contracts  with  reception  centers. 
(Who  provides  what  and  who  pays?) 

3.  There  are  no  adequate  plans,  equipment,  supplies  or  personnel  to 
implement  purposes  for  reception  centers.  (Such  as  contamination 
monitering,  decontamination,  congregate  care,  ...) 

4.  Public  shelter  locations  are  not  identified. 

5.  Adequate  plans  for  public  shelters  are  non-existent  (personnel, 
supplies,  etc.) 

6.  Resettlement  and/or  reentry  plans  have  not  been  formulated. 

7.  The  option  of  sheltering  in  private  homes  versus  evacuation  is  not 
addressed . 

RECOMMENDATIONS : 

1.  Define  specific  and  separate  functions  for  public  shelters  and  reception 
centers . 

2.  Specify  conditions  for  which  sheltering  in  private  homes  might  be 
preferable  to  evacuation. 

3.  Conduct  survey  of  potential  shelters  adequate  to  accommodate  peak  summer 
populations . 

4.  Identify  and  contract  for  an  adequate  number  of  reception  centers  and 
public  shelters  to  accommodate  EPZ  population. 

5.  Provide  adequate  plans  for  equipment,  supplies  and  personnel  for  centers 
and  shelters. 


68 


G.   MEDICAL  FACILITIES 
DEFICIENCIES: 

1.  There  are  inadequate  plans  for  treating  large  numbers  of  victims  of 
radiation  exposure. 

2.  The  two  hospitals  listed  in  the  Flan  (Jordan  and  St.  Luke's)  can  treat 
only  a  limited  number  of  people  with  radioactive  contamination. 

3.  One  hospital  is  within  the  EPZ  and  could  be  simultaneously  receiving  and 
evacuating  patients. 

RECOMMENDATIONS : 

1.  Clearly  determine  response  capacity  of  Jordan  and  St.  Luke's  Hospitals. 

2.  Identify  all  possible  referral  hospitals  outside  EFZ. 

3.  Document  capacity,  types  of  care  and  provisions  available  at  referral 
hospitals  outside  EFZ. 

4.  Obtain  signed  agreements  with  referral  hospitals. 

5.  Develop  procedures  for  transportation  of  patients  outside  the  EPZ. 

H.   RADIOFROTECTIVE  DRUGS 

PRESENT  POLICY: 

The  Massachusetts  Department  of  Public  Health  does  not  advise  distribu- 
tion to  the  general  public  of  Potassium  Iodide  (KI)  as  a  radioprotective 
drug. 

RECOMMENDATION: 

That  the  Department  of  Public  Health  provide  for  the  distribution  of 
Potassium  Iodide  or  a  proven  alternative  to  the  general  Plymouth  population 
prior  to  reactor  start-up. 


In  conclusion,  the  Committee  notes,  once  again,  that  the  deficiencies 
identified  herein  and  the  recommendations  made  relative  to  the  Plymouth  RERP 
are  by  no  means  exhaustive  or  all-inclusive.  Those  listed  are,  however, 
serious  enough  that,  were  they  not  to  be  addressed,  the  selectmen  might  be 
unable  to  "...  provide  for  the  health  and  safety  of  persons  and  their 
property  ..."  during  a  radiological  emergency.  Hence,  the  Committee  respect- 
fully urges  the  Selectmen  to  give  immediate  attention  to  the  matters  con- 
tained in  this  report.  Even  after  the  current  revision  of  the  RERP  and  the 
implementation  of  recommendations,  regular  monitoring  by  the  Town  will  be 
needed  so  that  improvements  in  the  plan  may  be  made  as  they  become  necessary. 


69 


TOWN  OF  PLYMOUTH 
COMMITTEE  ON  NUCLEAR  MATTERS 


COMMITTEE  REPORT 


ENVIRONMENTAL  RADIATION  MONITORING 
PILGRIM  NUCLEAR  POWER  STATION 


December  1987 


70 


COMMITTEE  MEMBERS: 


Grace  M.  Healy,  Chair 
Charles  W.  Adey,  Vice-Chair 
Ann  Waitkus  Arnold 
Theodore  L.  Bosen 
Marie  P.  Fehlow 
Kathleen  M.  Leslie 
Anthony  V.  Lonardo 
John  P.  Rooney 
Howard  E.  Shetterly 


SUBCOMMITTEE  MEMBERS: 


Kathleen  M.  Leslie,  M.D. 
Marie  P.  Fehlow,  R.N, 


The  Connnittee  thanks  Mrs.  Pauline  M.  Howe  for  her  invaluable 
assistance  in  editing  and  typing  this  Report. 


71 


REPORT  ON 

PILGRIM  NUCLEAR  POWER  STATION 

ENVIRONMENTAL  RADIATION  MONITORING 


OVERVIEW 

The  Committee  on  Nuclear  Matters,  in  an  attempt  to  understand  the  monitoring 
of  environmental  radiation  associated  with  the  Pilgrim  Nuclear  Power  Station, 
reviewed  documents  provided  by  Boston  Edison  and  interviewed  knowledgeable 
persons,  including  but  not  limited  to  Boston  Edison  representatives,  Nuclear 
Industry  representatives,  Department  of  Public  Health  representatives  and 
State  Officials. 

The  Committee  on  Nuclear  Matters  is  strongly  concerned  with  what  it  considers 
to  be  the  insufficient  number  of  monitoring  stations,  the  minimal  involvement 
of  the  State  in  the  monitoring  process,  and  the  complete  lack  of  an 
"oversight"  monitoring  system. 

The  Committee  respectfully  urges  the  Selectmen  to  consider  well  these 
recommendations  and  to  request  both  Boston  Edison  Company  and  the 
Commonwealth  of  Massachusetts  to  act  expeditiously  on  these  recommendations, 
which  the  Committee  considers  to  be  basic  and  modest. 


INTRODUCTION 

This  document  contains  Committee  recommendations,  with  a  sampling  of  the 
pertinent  materials  reviewed.   The  latter  are  intended  to  provide  some 
background  for  the  recommendations  made  herein. 

There  are  two  sections  in  this  document: 

Section  I:    Summary,  Conclusions  and  Recommendations 

Section  II:   Background  Materials 

*  Excerpts  from  PNPS-1  Environmental  Monitoring  Program  Reports 
Numbers  15,  17,  18. 

*  Excerpts  from  PNPS-1   Environmental  Monitoring  Program  Report 
Number  19  and  Radioactive  Effluent  and  Waste  Disposal  Report 
January  -  June  1987. 

*  Department  of  Public  Health  Monitoring  Program. 

*  Glossary 


It  should  be  noted  that  Section  II  is  only  an  outline  of  "Findings."  The 
reader  is  referred  to  the  complete  Boston  Edison  Program  Reports,  which  are 
available  at  the  Plymouth  Public  Library. 


72 


SECTION  I 
SUMMARY,  CONCLUSIONS  AND  RECOMMENDATIONS 

RADIATION  MONITORING  AMD  THE  PILGRIM  NUCLEAR  POWER  STATION 

SUMMARY 

1)  The  presence  of  Pilgrim  Nuclear  Power  Station  (PNPS)-related  isotopes 
has  been  documented  offsite  in  shellfish,  ocean  fish,  algae,  ocean  floor 
sediment,  and  garden  produce.  In  addition,  PNPS-related  isotopes  are 
present  in  water  samples  from  the  discharge  canal,  and  a  single  isotope, 
H-3  (Tritium),  has  been  found  in  a  nearby  pond.  Onsite  locations  that 
monitor  for  airborne  radiation  are  positive  for  Co-60  (Cobalt).* 

2)  Environmental  radiation  monitoring: 

a)  Airborne  radiation  is  measured  weekly  for  beta  particles, 
quarterly  for  gamma  radiation. 

b)  Thermoluminescent  Dosimeters  (TLDs),  which  monitor  gamma  radiation, 
are  analyzed  quarterly. 

c)  Liquid  effluent  from  the  plant's  discharge  canal  is  analyzed  weekly 
by  Boston  Edison  and  monitored  weekly  by  the  Department  of  Health 
(DPH). 

d)  Stack  monitors  which  record  gaseous,  particulate,  and  Iodine 
(1-131)  releases  from  PNPS  are  reviewed  weekly  by  the  DPH  and 
analyzed  weekly  by  Boston  Edison. 

3)  Monitoring  data  are  made  available  to  the  public  in  the  local  library 
six  months  after  the  year  ends.   (Environmental  Radiation  Monitoring 
Program  Report.) 

4)  The  NRC  has  faulted  Boston  Edison's  TLD  program  in  the  SALP  Report  for 
November  1,  1985  through  January  31,  1987: 

"...  problems  were  identified  in  the  licensee's  environmental 
thermoluminescent  dosimeter  (TLD)  program.   Commitments  made  by  the 
licensee  during  previous  assessment  periods  to  improve  the 
environmental  TLD  program  were  not  implemented.   Because  of  these 
problems,  the  validity  of  the  environmental  TLD  data  cannot  be 
assured.   This  indicated  lack  of  management  involvement  in  this 
area  and  a  lack  of  understanding  and  thoroughness  with  regard  to 
resolution  of  technical  issues." 

5)  Monitoring  of  residential  areas  contiguous  to  the  plant  is  virtually 
non-existent. 

6)  The  DPH,  NRC,  and  Boston  Edison  do  not  react  quickly  enough  and  strongly 
enough,  with  additional  monitoring  —  particularly  offsite,  when  there 
are  unplanned  radiation  releases. 

*  Throughout  this  report,  symbols  such  as  Co   ,  are  written  as  Co-60. 

This  representation  is  used  extensively  in  Boston  Edison  and  State  reports 
and  in  non-technical  informational  materials. 


73 


CONCLUSIONS 


All  of  the  Reports  reviewed  by  the  Committee  on  Nuclear  Matters  (1982-1987) 
indicate  to  its  members  that  the  Pilgrim  Nuclear  Power  Plant  does  have  a 
continuing  environmental  impact.   In  all  of  the  materials  reviewed,  however, 
Boston  Edison  Company,  the  N.R.C.,  and  the  Commonwealth  hold  that  offsite 
releases  from  the  Plant  (as  indicated  by  current  monitoring)  have  not 
exceeded  technical  specifications.   Boston  Edison  Company,  the  N.R.C.,  and 
the  Commonwealth  then  draw  the  conclusion  that  there  has  been  no  measurable 
impact  upon  the  citizenry.   They  further  claim  that  even  if  there  had  been 
any  impact  it  would  have  been  minimal,  and  far  less  than  the  effects  of 
previous  worldwide  weapons  testing  or  of  the  Chernobyl  accident. 

The  Committee  on  Nuclear  Matters  takes  little  comfort  in  the  above 
comparisons.   Any  environmental  impact  is  of  concern  and  needs  to  be  examined 
if  public  health  is  to  be  protected.   The  Committee  questions  the  adequacy  of 
current  monitoring  around  Pilgrim  I,  even  though  it  may  be  more  extensive 
than  that  at  some  other  nuclear  plants.   Hence,  the  Committee  recommends 
increased  monitoring,  higher  quality  monitoring,  proper  timing  of  monitoring 
to  reveal  effects  of  specific  plant  incidences  which  involve  radioactive 
releases,  and  prompt  reporting  of  the  results.  Accomplishment  of  these 
recommendations  is  basic  to  an  investigation  of  the  impact  of  PNPS  upon 
citizens'  health. 


74 


RECOMMENDATIONS 


1.  The  Commonwealth  of  Massachusetts  should  establish  a  comprehensive, 
state-of-the-art  radioactive  monitoring  system,  the  purpose  of  which  is 
to  measure  instantaneously  the  type  and  quantity  of  radioactive 
emissions  and  effluents  at  each  release  point  of  nuclear  reactors.   The 
intent  of  the  Committee  in  this  recommendation  is  the  establishment  of 
an  independent  monitoring  (oversight)  system  which  will  go  far  beyond 
the  minimum  monitoring  now  done  by  the  Department  of  Public  Health. 

2.  Such  a  system  will  require  substantial  resources.   To  that  end,  the 
owners  of  nuclear  power  plants  within  the  Commonwealth  of  Massachusetts 
should  be  assessed  the  costs  of  establishing  and  operating  the 
comprehensive,  state-of-the-art  monitoring  system. 

3.  Since  an  extended  time  period  will  be  involved  in  bringing  this 
comprehensive  monitoring  system  on  line,  the  following  immediate 
response  is  recommended: 

As  an  interim  measure,  the  committee  recommends  that  a  qualified  state 
team  should  be  established  as  soon  as  possible  to  monitor  plant 
activities  relative  to  radiological  releases  which  affect  the  well-being 
of  the  citizenry.   This  team  will  be  located  onsite  and  report  to 
appropriate  State  decision  makers.   This  will  not  be  a  continuing 
arrangement,  but  merely  a  first  step  toward  the  permanent  system 
specified  in  recommendation  number  1. 

4.  Boston  Edison  should  increase  its  air  particulate,  gaseous  radioiodine 
and  soil  surveillance  stations.   These  additional  stations  should  be 
adequate  to  ensure  that  no  substantial  radioactive  material  can  be 
released  without  detection. 

5.  Boston  Edison  should  install  additional  TLD's  around  the  Plant  to  ensure 
reliable  quantification  of  total  offsite  dose  rate. 

6.  Boston  Edison  should  increase  the  numbers  of  samples  collected  and  the 
locations  and  frequency  of  collection  of  shellfish. 

7.  Boston  Edison  should  improve  quality  control  with  respect  to  its 
radiation  monitoring  so  that  equipment  failure  is  immediately 
recognized. 


75 


SECTION  II 
BACKGROUND  MATERIALS 


PILGRIM  NUCLEAR  POWER  STATION 
ENVIRONMENTAL  RADIATION  MONITORING  PROGRAM 

Excerpts  from  REPORT  NO.  18  (1985),  REPORT  NO.  17  (1984)  and  REPORT  NO.  15 
(1982). 

ENVIRONMENTAL  RADIATION 

A.  AIRBORNE 

Airborne  radiation  is  monitored  at  the  locations  listed  by  Boston  Edison 
in  table  4.8.2.  of  Report  #18.   (See  the  following  page.)   Particulates, 
radioiodine,  and  soil  are  sampled.   The  collection  system  consists  of  a 
cellulose  particulate  filter  and  a  charcoal  filter  cartridge  which  are 
used  to  collect  particulate  matter  and  iodine  nuclides  respectively. 
Analyses  of  the  particulate  filters  for  beta  radiation  is  performed 
weekly.   1-131  analyses  are  performed  weekly  as  well.   In  addition 
quarterly  composite  particulate  samples  are  tested  for  gamma  emitting 
nuclides.   Soil  analyses  are  performed  once  per  three  years  for  gamma 
isotopes. 

FINDING 

Cobalt  (Co-60),  attributed  to  operation  of  PNPS,  has  been  found  at 
onsite  locations  including  the  overlook,  pedestrian  bridge,  and 
warehouse.   It  has  been  identified  in  the  soil  at  the  pedestrian  bridge. 

B.  DIRECT 

Dosimeters,  located  at  twenty  areas  (as  listed  in  table  4.8.3)  are 
analyzed  on  a  quarterly  basis  for  gamma  radiation. 

FINDING 

According  to  Boston  Edison,  "beyond  the  'exclusion  area'  (for  this 
purpose,  the, 0.25-0.7  mile  region),  dose  rates  show  no  significant  plant 
effect " 


Environmental  Radiation  Monitoring  Program,  Report  No.  18  (1985), 
pp.  3-16,  3-17. 


76 


4'    B 
w    o 

C     u 

■-*   o 
a  — 


o    c 

■T3     w 


^  —  -— 


O  ■^^  ,_ 


O.  .J  w 

u  3  a 

■HOW 

<  ^  o 

■a  —  J3 

:>  3 

o  ja  o 

fc  "  g. 


I    B 


g     ^ 


>  ■•*         ._ 


^     5 


o 

M 

^ 

U 

■a 

o 

u 

C 

o 

b 

S 

o 

u 

;k 

c 

9 

« 

o 

c 

3 

u 

H 

a 

M 

2     g     -,    „    -     = 


■O  ^_  ^^ 


a 


<§ 


77 


C.  WATERBORNE 

Waterborne  radiation  is  monitored  at  the  plant's  discharge  canal,  at 
Bartlett  Pond  (which  is  1.7  miles  SE  of  the  plant)  and  at  Powder  Point 
Bridge  (which  is  7.8  miles  NNW  of  the  plant).   Discharge  canal  samples 
are  collected  every  one-half  hour;  weekly  "grab  samples"  are  taken  from 
the  Bartlett  Pond  and  from  Powder  Point  Bridge  seawater.   Analysis  is 
monthly  for  gamma  isotopes  and  quarterly  for  H-3 . 

FINDING 

Cesium  (Cs-137),  Cobalt  (Co-60),  and  Tritium  (H-3)  have  been  present  in 
discharge  canal  samples.   H-3  has  been  found  at  Bartlett  Pond.   These 
isotopes,  according  to  Boston  Edison,  are  attributed  to  operation  of 
PNPS. 

D.  AQUATIC 

Aquatic  samples  include  shellfish,  Irish  moss  (algae),  lobster,  fish  and 
ocean  floor  sediments. 

1.  Shellfish 

Shellfish  samples  are  analyzed  quarterly  for  gamma  isotopes. 
Locations  sampled  are  discharge  outfall,  Duxbury  Bay,  Manomet 
Point,  Plymouth  or  Kingston  Harbor,  and  Marshfield. 

FINDING 

Samples  from  the  discharge  canal  have  been  positive  for  Mn-54, 
Zn-65,  Co-60,  Co-58,  and  C8-137.   Samples  from  Manomet  Point  have 
been  positive  for  Mn-54,  Co-60,  Cs-137,  Zn-65.   Testing  for  Co-60, 
Cs-137  has  been  positive  in  Warren  Cove  samples.   According  to 
Boston  Edison,  all  of  these  isotopes  are  attributable  to  operation 
of  PNPS.  

2.  Algae 

Algae  samples  are  collected  quarterly  from  the  discharge  canal, 
Manomet  Point,  and  Ellisville. 

FINDING 

Samples  from  the  discharge  canal  have  demonstrated  Zn-65,  Cs-137, 
Mn-54,  Co-58  and  Co-60.   Algae  from  Manomet  Point  have  demonstrated 
Mn-54  and  Co-60.   Ellisville  has  been  positive  for  Mn-54  and  Co-60. 
According  to  Boston  Edison,  all  of  these  isotopes  are  attributable 
to  operation  of  PNPS. 

3.  Lobster 

Lobster  is  collected  four  times  per  season  in  the  vicinity  of 
discharge  point  and  annually  offshore.   It  is  analyzed  for  gamma 
isotopes. 

FINDING 

No  plant  attributable  isotopes  were  found. 

7 


78 


4.  Fish 

Gamma  isotopic  analyses  are  performed  from  four  separate  fish 
groups:  bottom  oriented,  near  bottom,  anadromous,  and  coastal 
migratory.   They  are  caught  in  the  vicinity  of  the  discharge  canal 
as  well  as  at  a  control  point  at  a  distance  offshore.   Analysis  is 
quarterly  for  bottom  and  near  bottom  fish,  in  season  for  anadromous 
and  coastal  migratory.   A  control  analysis  from  fish  caught 
offshore  is  performed  annually. 

FINDING 

j    Bluefish  and  cod  samples  from  the  discharge  canal  have  been 
/    positive  for  Cs-137.   A  salmon  sample  from  the  mouth  of  the  North 
/    River  in  Hanover  was  positive  for  Cs-137.   This  isotope  was 
<     attributed  by  Boston  Edison  as  being  due  to  radioactive  releases 
— from  PNPS. 

5.  Sediments 

Sediment  samples  are  taken  semi-annually  at  Rocky  Point,  Warren 
Cove,  Plymouth  Harbor,  Duxbury  Bay,  Plymouth  Beach,  Manomet  Point, 
and  a  control  point  in  Marshfield. 

FINDING 

Analyses  performed  at  Duxbury  Bay,  Plymouth  Beach,  Warren  Cove, 
and  Marshfield  demonstrated  Cs-137.   This  is  attributed  "....to 
some  extent..."   to  the  fission  products  related  to  fallout  from 
previous  weapons  testing.   Rocky  Point,  Manomet  Point,  Duxbury  Bay 
have  had  positive  values  for  Co-60  which  Boston  Edison  attributes 
to  operation  of  PNPS. 

E.   TERRESTRIAL 

Terrestrial  samples  include  milk,  cranberries,  vegetables,  and  beef 
forage  or  cattle  feed. 

1.  Milk 

Milk  is  collected  from  the  cows  at  the  Plymouth  County  Farm  and 
Whitman  Farm,  semi-monthly  when  the  animals  are  on  pasture, 
otherwise  at  a  monthly  interval.   Analyses  for  gamma  isotopes, 
Sr-87,  Sr-90,  and  1-131  are  performed. 

FINDING 

The  1982  Report  states  that  of  the  isotopes  present,  i.e.,  Sr-90, 
Sr-89,  Cs-137,  ",..PNPS-1  probably  contributed  much  less  than  0.01% 
of  the  measured  concentration..."   Most  is  attributed  by  Boston 
Edison  to  fallout  from  nuclear  weapons  testing. 


Environmental  Radiation  Monitoring  Program,  Report  No.  17  (198A), 
p.  3-47. 

8 


79 


2.   Cranberries 

Cranberries  from  a  Manomet  Point  Bog  (2.6  miles  SE),  Bartlett  Road 
Bog  (2.8  miles  SSE/S),  and  Pine  Street  Bog  (17  miles  WNW)  are 
analyzed  for  gamma  isotopes  at  the  time  of  harvest. 

FINDING 

Cs-137  has  been  found  at  the  Manomet  Point  Bog  at  a  level 
greater  than  ten  times  average  background  for  that  isotope.   A 
comprehensive  study  of  cesium  uptake  in  cranberries  was  performed 
during  1978.   This  report  identified  fallout  from  previous  nuclear 
weapons  testing  as  the  primary  source  of  cesium  in  cranberries. 

3.  Vegetables 

Vegetable  samples  are  collected  at  the  Karbott  Farm  and  Bridgewater 
Farm  as  well  as  other  nearby  gardens. 

FINDING 

Co-60  at  farms  1.5  miles  SSW  and  1.0  miles  W  were  attributed  to 
controlled  releases  from  PNPS.   In  addition,  Cs-137  present  in  the 
sample  at  the  farm  1.5  miles  SSW  was  attributed  to  PNPS. 

4.  Beef  Forage 

Beef  forage  is  tested  annually  from  the  Plymouth  County  Farm, 
Whitman  Farm,  and  Bridgewater  Farm. 

FINDING  i 

No  plant  related  isotopes  have  been  found. 


It  might  be  of  interest  to  the  reader  to  note  the  selected  gamma  exposure 
data  from  the  1982  Report  which  are  found  on  the  following  pages.   If  one 
compares  gamma  exposure  across  each  of  the  quarters  at  each  station  listed, 
one  can  clearly  see  some  patterns  of  increased  exposure.   There  are,  however, 
inconsistencies  between  the  distance  of  some  stations  from  the  Plant  and  the 
level  of  reading  obtained  during  a  given  quarter. 

Such  inconsistency  needs  to  be  addressed  by  Boston  Edison  and  by  the 
Commonwealth.   At  the  least,  there  should  be  an  increase  in  the  numbers  of 
TLD's,  particularly  in  areas  contiguous  to  the  Plant.   Stations  should  form 
a  tight  ring  around  the  plant  and  rings  should  be  replicated,  as  far  as 
feasible,  in  circles  of  widening  radii. 


Environmental  Radiation  Monitoring  Program,  Report  No.  15  (1982), 
p.  3-69. 


80 


GAMMA  EXPOSURE  (TLD)  SELECTED  DATA  FOR  FOUR  QUARTERS  OF  1982 


Distance  and  Microrads  per  Hour 

Station  Location       Direction  .  Quarter  of  1982: 

(Designation)        from  Reactor        First   Second   Third  Fourth 


OFFSITE  STATIONS: 

East  Weymouth  (EW)  *  23  miles  NW 

Kingston  (KS)  10  Miles  WNW 

Sagamore  (CS)  10  miles  SSE-S 

Plymouth  Airport  (SA)  8  miles  WSW 

North  Plymouth  (NP)  5.5  miles  WNW 

Plymouth  Center  (PC)  4.5  miles  W-WNW 

South  Plymouth  (SP)  3  miles  WSW 

r-  1^    Manomet  (MS)  2.5  miles  SSE 

.^  Manomet  (ME)  2.5  miles  SE 

--   Manomet  (MP)  2.25  miles  ESE-S 

^  Cleft  Rock  Area  (CR)  0.9  miles  S 

*         Control  Station. 

ND   No  Data  due  to  missing  TLD. 

Continued 
10 


4.00 

8.30 

11.84 

8.62    74c_,^ 

4.41 

6.45 

8.14 

8.55    ^-^v, 

5.22 

ND 

6.82 

6.50   ^G^j-u 

2.68 

5.89 

15.40 

6.87    ^^(^.^ 

4.59 

8.47 

14.11 

8.21  -iU.,^ 

ND 

4.60 

7.62 

6.01    y'llo^^^ 

5.91 

6.80 

12.91 

6.61  °i  ^^J 

4.73 

8.28 

20.77 

9.28    <5U.^^ 

6.46 

9.33 

16.43 

HD     Vl«^ 

5.11 

7.19 

10.91 

7-59    Hv,,^ 

7.97 

8.89 

15.52 

8.57    -/^o^ 

81 


GAMMA  EXPOSURE  (TLD)  SELECTED  DATA  FOR  FOUR  QUARTERS  OF  1982 

Distance  and  Microrads  per  Hour 

Station  Location        Direction         Quarter  of  1982: 

(Designation)        from  Reactor        First   Second   Third   Fourth 


ONSITE  STATIONS 

Rocky  Hill  Road  (ER)  0.8  miles  SE 

Microwave  Tower  (MT)  0.38  miles  S 

Rocky  Hill  Road  (WR)  0.3  miles  W-WNW 

Rocky  Hill  Road  (B)  0.26  miles  SSE 

Property  Line  (H)  0.21  miles  SSW 

Property  Line  (I)  O.IA  miles  W 

Public  Park.  Area(PA)  0.07  miles  N-NNE 

Overlook  Area  (OA)  0.03  miles  W 

Property  Line  (PL)  0.34  miles  NW 

Ped.  Bridge  (PB)  0.14  miles  N 

East  Breakwater  (EB)  0.35  miles  ESE 

Warehouse  (WS)  0.03  miles  SSE 


4.63 

6.14 

6,91 

10.84 

^^/^c^ 

4.06 

9.55 

13.21 

9.44 

A.J 

4.64 

11.22 

17.15 

9.85 

4.02 

8.94 

8.28 

11.15 

k<Uo^ 

8.11 

15.97 

11.43 

12.89 

4.34 

8.98 

10.93 

9.31 

5.07 

8.73 

11.26 

7.30 

lyeio  K^ 

6.95 

22.51 

30.99 

22.97 

^J^-"  i-'t^ 

4.38 

7.29 

11.75 

10.31 

^-^ 

8.32 

17.49 

22.81 

17.60 

^^^ 

4.84 

8.18 

10.10 

7.77 

6.38 

10.83 

26.60 

14.03 

q.i^-s 

Geographic  Regional  Averages: 

Near  Plant           0  -  0.16  miles  09.18  14.89  22.92  15.47 

Exclusion  Area        0.25  -  0.68  miles  5.54  9.10  11.22  9.56 

Distant  Neighborhood  0.7  -  6.5  miles  4.39  8.03  11.74  7.86 

Background           8-21  miles  4.08  6.87  10.55  7.63 

*    Control  Station. 

ND   No  Data  due  to  missing  TLD. 

11 


82 


PILGRIM  NUCLEAR  POWER  STATION 

ENVIRONMENTAL  RADIATION  MONITORING  PROGRAM 

Report  Number  19 

January  1  -  December  31,  1986 

The  following  information  was  excerpted  from  the  above  mentioned  report  when 
it  became  available  from  Boston  Edison  Company.   Only  "Findings"  are  included 
herein  since  explanations  of  data  collection  locations  and  methods  were 
described  earlier. 

RESULTS  OF  ANALYSES 

A.  AIR  PARTICULATE  FILTERS 

FINDING 

There  were  no  positive  measurements  of  any  nuclides  characteristic  of 
reactor  operations  attributable  to  PNPS-1  observed  in  the  quarterly 
composite  samples.   There  were  positive  measurements  of  nuclides 
characteristic  of  reactor  operations  attributable  to  the  Chernobyl 
Nuclear  Power  Plant  accident  in  the  second  quarter  composite  samples. 
These  nuclides  were:  Ru-103,  Cs-134  and  Cs-137.   In  addition,  high 
concentrations  of  Be-7  were  also  seen. 

B.  IODINE 

FINDING 

As  a  result  of  the  Chernobyl  accident,  positive  indications  of  1-131 
were  detected  in  the  charcoal  filters  in  all  stations  from  week  #20 
through  week  #24  (late  May  to  early  June)  with  the  highest 
concentrations  seen  during  week  #21. 

C.  SOIL 

FINDING 

Soil  analyses  are  performed  once  every  three  years  for  gamma  isotopes. 
See  1982  report. 

D.  DIRECT  RADIATION 

1.  CONTINUOUS  TLD 

FINDING 

Beyond  the  "exclusion  area"  (for  this  purpose,  the  0.25-0.7  mile 
region),  dose  rates  show  no  significant  plant  effects. 

2.  FIELD  SURVEY 

FINDING 

Survey  results  are  within  the  expected  natural  background  exposure 
rates  in  the  northeastern  part  of  the  United  States. 

12 


83 


E .  WATERBORNE 

FINDING 

There  were  no  positive  measurements  of  nuclides  characteristic  of 
reactor  operation  observed  at  any  of  the  three  sampling  locations.  The 
only  positive  measurements  observed  were  due  to  naturally  occurring 
nuclides  (K-40  and  AcTh-228). 

F.  SHELLFISH 

FINDING 

There  have  been  positive  measurements  of  Be-7,  Mn-54,  Co-60,  AcTh-228 
and  K-AO  in  samples  from  the  Discharge  Canal.   In  addition,  there  have 
been  positive  measurements  of  Be-7,  AcTh-228  (peak)  and  K40  at  Warren 
Cove;  AcTh-228  and  K-40  at  Duxbury  Bay;  and  Be-7,  AcTh-228  and  K-40  at 
the  control  station  in  Marshfield.   Tl\|gj;:£_vrasone  positive  measurement 
of  Ru-103  at  Manomet  Point  in  a  sample  which  was  collected  on  7/8/86. 


The  observed  concentrations  of  Mn-54  and  Co-60  were  the  result  of  PNPS-1 
liquid  releases.  "Qie   contribution  of  Ru-103  was  due  to  Chernobyl- 
related  radioactivity^  The  observed  concentrations  of  Be-7,  AcTh-228 
and  K-40  are  due  to  the  natural  occurrence  of  these  nuclides. 

G.  ALGAE  (IRISH  MOSS) 

FINDING 

There  have  been  positive  measurements  of  Be-7,  Co-60,  Ru-103  and  K-40  at 
the  Discharge  Canal.   In  addition,  there  have  been  positive  measurements 
of  Be-7,  Co-60,  Ru-103,  1-131,  AcTh-228  and  K-40  at  Manomet  Point 
(Station  15-3  miles-SE);  and  Be-7,  Co-60,  AcTh-228  and  K-40  at  the 
control  station  at  Ellisville  (Station  22-8  mi-SSE). 

The  measured  concentrations  of  Co-60  at  the  Discharge  Canal  are 
certainly  due  to  liquid  effluents  from  PNPS-1.   The  observed 
concentrations  of  Co-60  at  Manomet  Point  and  Ellisville  were  the  result 
of  PNPS-1  liquid  releases.  The  highest  concentration  of  Co-60  was  seen 
at  the  Discharge  Canal. 

H.   LOBSTER 

FINDING 

The  results  are  unremarkable  in  that  there  were  no  positive  measurements 
of  any  isotopes  other  than  K-40  in  either  the  indicator  or  the  control 
samples  (K-40  is  a  naturally  occurring  nuclide). 


13 


84 


I.  FISH 

FINDING 

A  striped  bass  sample  collected  on  10/2/86  at  the  Discharge  Canal 
Outfall  Area  indicated  a  positive  measurement  of  Cs-137. 

J.   SEDIMENTS 

FINDING 

It  is  clear  that  positive  measurements  of  Co-60  and  Cs-137  were 
observed.   The  highest  concentration  of  Co-60  was  observed  in  a  sediment 
sample  (24-26  cm)  taken  from  Rocky  Point  (Station  11)  on  5/19/86.   In 
addition,  Co-60  was  observed  in  all  of  the  sediment  segments  (0-30  cm) 
obtained  from  Rocky  Point  on  5/19/86  and  in  two  sediment  segments  (16-20 
cm)  from  Duxbury  Bay  collected  on  5/29/86.   The  concentrations  of  Co-60 
at  Rocky  Point  are  due  to  liquid  .affluents  from  PNPS-1 .   The 
concentration  of  Cs-137  at  the  24-26  cm  level  from  Rocky  Point  was  most 
likely  due  to  controlled  liquid  releases  from  PNPS-1.   The  measured 
concentration  of  Be-7 ,  and  to  some  extent  Cs-137,  at  Duxbury  Bay, 
Plymouth  Harbor  and  Marshfield  are  attributable  to  the  fission  products 
related  to  fallout  from  previous  weapons  testing.  , 

K.   MILK 

FINDING 

The  positive  measurements  of  1-131  in  the  samples  from  week  #19  through 
week  #27  (late  May  until  early  July),  and  the  positive  measurements  of 
Cs-134  and  Cs-137  from  week  #21  through  week  #27  were  attributable  to 
Chernobyl-related  radioactivity.   There  was  only  a  small  amount  of 
strontium  released  during  the  Chernobyl  accident  which  resulted  in 
negligible  Sr-89  and  Sr-90  in  the  Chernobyl-related  radioactivity. 

The  highest  concentration  of  Sr-90  occurred  at  Plymouth  County  Farm 
(collected  on  9/4/86)  and  the  highest  concentration  of  Sr-89  occurred  at 
the  Plymouth  County  Farm  (collected  on  6/19/86).   However,  there  were  no 
positive  measurements  made  of  either  Sr-89  or  Sr-90,  there  were  only 
indications  of  the  presence  of  Sr-90.   It  is  unlikely  that  PNPS-1  is  the 
major  source  of  the  indicator  station  activity. 

Prior  to  week  #21  and  after  week  #27,  the  highest  concentration  of 
Cs-137  occurred  at  Plymouth  County  Farm  (3.5  mi-W)  in  early  September 
(Collected  on  9/4/86).   Edison  claimed  that  the  primary  source  of  Cs-137 
was  other  than  PNPS-1,  and  was  most  likely  due  to  fallout  from  previous 
atmospheric  weapons  testing. 


14 


85 


L.   CRANBERRIES 

FINDING 

The  only  manmade  radionuclide  detected  was  Cs-137,  which  appeared  in  the 
Manomet  Point  Bog  sample  (collected  on  9/23/86).   Claim  was  again  made 
that  the  measured  concentration  was  due  to  fallout  from  previous  weapons 
testing  and  a  lack  of  adequate  potassium  in  the  soil. 

M.   VEGETATION 

FINDING 

The  only  nuclides  observed,  other  than  naturally  occurring  Be-7, 
AcTh-228  (peak)  and  K-40,  was  Cs-137.  A  positive  measurement  of  Cs-137 
was  detected  in  vegetation  collected  from  two  locations  on  9/16/86. 
Because  of  the  absence  of  Cs-134  Edison  again  concluded  that  weapons 
testing  fallout  was  the  primary  source  of  Cs-137. 

N.   FORAGE 

FINDING 

The  following  positive  measurements  were  detected  at  two  stations:  Be-7, 
Ru-103,  Cs-134,  Cs-137  and  K-40.   The  beef  forage  samples  were  both 
collected  on  6/19/86.   Edison  again  concluded  that  the  contribution  of 
Ru-103,  Cs-134,  and  Cs-137  were  due  to  the  Chernobyl  accident. 


In  addition  to  the  above  data  from  the  1986  Report,  some  data  from  the 
Radioactive  Effluent  and  Waste  Report  (January  -  June  1987)  can  be  found  on 
the  following  page.   These  data  are  of  interest  in  that  they  demonstrate 
continued  releases  of  materials  into  Cape  Cod  Bay  during  periods  of  Plant 
shut-down.   Plant  decontamination  accounts  for  increased  numbers  of  batch 
releases.   (The  decrease  in  average  stream  flow  in  number  6  was  due  to  the 
use  of  one  pump  rather  than  three.) 


15 


86 


SOURCES  OF  DATA: 


PILGRIM  NUCLEAR  POWER  STATION 
ENVIRONMENTAL  RADIATION  MONITORING  PROGRAM 
REPORT  NUMBER  19 
January  1  -  December  31,  1986 


AND 


RADIOACTIVE  EFFLUENT  AND  WASTE  DISPOSAL  REPORT 
January  1  -  June  30,  1987 


BATCH  RELEASES  OF  RADIOACTIVE  MATERIALS  IN  LIQUID  EFFLUENTS 

INTO  CAPE  COD  BAY 

January      July  to      January 

to  June      December     to  June 

1986        1986        1987 


1.   Number  of  batch  releases  143 


125         211 


2.  Total  time  period  for 

batch  releases  (Hours)  368.7        216.7        439.7 

3.  Max-i'mum  time  period  for 

a  batch  release  (Hours)  8.42        10,4         16.2 

4.  Average  time  period  for 

batch  releases  (Hours)  2.57         1.7  2.0 

5.  Minimum  time  period  for 

a  batch  release  (Hours)  0.25         0.08         0.25 

6.  Average  stream  flow  during  periods 
of  release  of  effluent  into  a 
flowing  stream  (Gallons  per 

""■""'^^  234,500      155,000      79,200 


16 


87 


DEPARTMENT  OF  PUBLIC  HEALTH  RADIATION  MONITORING  PROGRAM 

This  report  is  based  upon  data  supplied  to  Dr.  Kathleen  Leslie  and  Ms.  Marie 
Fehlow  by  Robert  M.  Hallisey,  Director,  Radiation  Control  Program, 
Massachusetts  Department  of  Public  Health  (DPH). 

The  DPH  monitors  radiation  emissions  from  PNPS  via  three  routes: 

(1)  thermoluminescent  dosimeters  (TLDs),  (2)  main  stack  and  reactor  building 

vent  monitors,  and  (3)  discharge  canal  releases  recording  equipment. 

A.  TLDs 

DPH  TLDs  have  been  in  place  since  the  third  quarter  of  1981.   They  are 
located  at  twenty-four  sites  within  a  five-mile  radius  of  the  plant. 
TLDs  measure  gamma  radiation  and  are  read  quarterly.   Some  State  TLDs 
are  located  together  with  those  of  Boston  Edison  and  the  NRC ,  some  are 
located  separately.   According  to  Mr.  Hallisey,  monitoring  is  necessary 
only  within  the  five-mile  radius  because,  should  increases  in  radiation 
levels  be  demonstrated  close  to  the  Plant,  "doses  at  further  distances 
can  be  calculated  using  the  inverse  square  law." 

FINDING 

The  State  has  not  found  any  levels  of  radiation  that  exceed  background 
at  their  TLD  stations. 

B.  Stack  Emissions 

The  DPH  visits  PNPS  weekly  to  inspect  the  automatic  strip  chart  recorder 
from  the  main  stack  and  the  reactor  building  vent  for  quantitative 
release  rates  from  each  stack  of  gaseous  effluents,  particulates,  and 
1-131. 

FINDING 

Inspection  of  reports  from  1/86  -  10/86  revealed  no  gaseous  releases 
which  exceeded  technical  specifications. 

C.  Liquid  Releases 

The  DPH  visits  PNPS  weekly  to  inspect  the  recording  of  liquid  releases 
from  PNPS  into  the  ocean. 

FINDING 

Inspection  of  reports  from  1/86  -  10/86  revealed  no  releases  of  liquid 
effluents  which  exceeded  technical  specifications. 


17 


88 


GLOSSARY 

1)  Radiation  -  Radiation  is  energy  in  the  form  of  waves  or  particles  that 
can  penetrate  matter.  Although  the  term  "radiation"  includes  such 
things  as  light  or  radio  waves,  it  is  most  often  used  to  mean  "ionizing" 
radiation,  which  can  produce  charged  particles  ("ions")  in  materials  it 
strikes . 

2)  Ionizing  radiation  -  Has  the  ability  to  knock  electrons  out  of  atoms, 
creating  electrically  charged  ions.   These  ionized  atoms  have  the 
ability  to  damage  living  tissue.   Examples:  x-rays,  gamma  rays,  alpha 
particles . 

3)  Nonionizing  radiation  -  Does  not  have  the  above  property.   Examples: 
microwaves,  sound  waves,  light. 

4)  Radioactivity  -  Results  from  the  release  of  radiation  from  the  nucleus 
of  an  atom  with  an  unstable  ratio  of  protons  to  neutrons  in  order  to 
achieve  stability. 

5)  Particulates  -  Microscopic  particles  that  may  be  radioactive. 

6)  Noble  gas  -  A  gas  that  is  chemically  and  biologically  nonreactive,  e.g., 
xenon  and  krypton. 

7)  Alpha  radiation  -  Consists  of  positively  charged  particles.  Alpha 
radiation  will  be  stopped  by  the  outer  layer  of  skin;  it  can  be  stopped 
completely  by  a  sheet  of  paper.   However,  the  potential  hazard  from 
alpha  emitting  materials  is  due  to  the  possibility  of  internal 
deposition  to  the  body  by  ingestion  or  inhalation. 

8)  Beta  radiation  -  Beta  particles  are  similar  to  electrons,  but  originate 
in  the  nucleus  of  the  atom.   Beta  is  more  penetrating  than  alpha 
radiation  and  can  pass  through  0.5-1  centimeter  of  water  or  human  flesh. 
A  sheet  of  aluminum  a  few  millimeters  thick  can  stop  beta  radiation. 
There  is  also  an  inhalation  hazard  from  beta  radiation. 

9)  Gamma  radiation  -  Consists  of  photons  (wave  energy)  that  can  be  very 
penetrating.  Depending  on  the  energy  levels,  gamma  radiation  can  pass 
through  the  body.  Dense  materials  such  as  concrete  and  lead  are  used 
for  shielding  against  gamma  radiation. 

10)  Effluent  (radiological)  -  Release  of  radionuclides  originating  from  the 
reactor  vessel  into  the  environment. 

11)  Manmade  radiation  -  Radiation  from  medical  and  dental  use  of  X-rays  and 
radioactive  materials  to  diagnose  and  treat  disease,  giving  an  average 
dose  of  90  mr/year/person.  Another  10  mr/year/person  are  received  from 
fallout  from  nuclear  weapons  testing,  nuclear  power  plants,  industrial 
uses  of  radioactive  materials  and  minute  emissions  from  certain  consumer 
products  such  as  color  television  sets. 

Continued 
18 


89 


GLOSSARY  (Continued) 

12)  Natural  background  radiation  -  Radiation  from  natural  sources  such  as 
cosmic  rays,  granite,  natural  gas;  an  average  of  100  millirems/year/ 
person. 

13)  Rad  -  Radiation  absorbed  dose  or  amount  of  energy  deposited  in  living 
tissue  by  ionizing  radiation. 

14)  Rem  -  A  unit  for  measuring  the  biological  effects  on  a  person  from  a 
dose  of  radiation.   A  rem  of  exposure  produces  a  constant  biologic 
effect  regardless  of  the  type  of  radiation. 

15)  Millirem  -  1/1000  of  a  rem. 


19 


90 

The  Chairman.  Thank  you,  Dr.  Healy.  I  think  we'll  hear  more 
about  some  of  these  issues  when  we  hear  from  some  of  our  State 
officials  and  the  relationship  between  their  authority  and  the 
power  of  the  Federal  Regulatory  Commission,  and  I  look  forward  to 
that. 

Let  me  ask  you.  Dr.  Healy.  You're  familiar  with  Dr.  Cobbs' 
report  about  the  increased  leukemia  rates  that  he  discovered? 

Dr.  Healy.  Yes. 

The  Chairman.  And  we'll  make  that  report  a  part  of  the  record. 
Rather  than  my  reading  through  that,  perhaps  you  could  briefly 
describe  the  conclusions. 

Dr.  Healy.  Well,  what  Dr.  Cobbs  did  is  he  made  note  of  the 
highly  unusual  incidents  of  leukemia  in  a  five-town  range,  which 
includes:  Plymouth,  Kingston,  Duxbury,  Marshfield,  and  Scituate 
and  what  he  attempted  to  do  was  to  connect  this  incident  with  ra- 
dioactive emissions  from  the  plant. 

What  he — my  understanding  is  what  he  hypothesized  was  that 
the  topography,  the  coastal  wind  circulation  and  the  coastal  fogs 
formed  a  natural  barrier,  which  would  hold  and  entrap  radioactive 
residues  from  Pilgrim  I. 

Our  committee  is  aware  that  there  is  some  disagreement  with 
the  topography-wind  hypothesis,  but  we  are  checking  into  it  with 
our  experts,  but  quite  frankly,  Mr.  Chairman,  our  committee  is  not 
so  much  interested  in  such  theories.  We  are  far  more  interested  in 
the  data  that  we  can  get  from  the  field,  and  those  data,  and  only 
those  data,  we  feel  from  the  monitoring,  are  going  to  allow  us  to 
get  to  any  causal  inferences,  and  we  strongly  recommend 

The  Chairman.  Now,  the  State  has  looked  into  this  as  well,  has 
it  not? 

Dr.  Healy.  The  State  has  used  data  from — my  understanding  is 
that  the  State  has  analyzed  and  reanalyzed  data  from  the  Cancer 
Registry,  but  those  data  our  committee  feels  are  flawed  in  that  the 
procedures  and  the  methodology  are  flawed.  It  is  my  understanding 
that  they  are  moving  toward  a  comprehensive  study  at  this  time, 
but  our  committee  will  be  recommending  that  we  go  far  beyond  the 
State  to  the  national  level. 

The  Chairman.  I  think  the  suggestions  which  you  make,  and 
which  Mary  Ott  and  others  have  made  with  regard  to  health  stud- 
ies are  excellent  suggestions,  as  we  have  heard  in  your  testimony, 
and  read  about  in  preparation  for  the  hearing,  and  also  in  some  of 
the  communications  that  we  have  received  from  many  of  you  and 
from  others.  It  seems  that  the  kind  of  pattern  that  we  have  heard 
here  is  very  similar  to  the  type  of  pattern  that  we  heard  about  in 
connection  with  Three  Mile  Island  in  1979  when  this  committee 
held  hearings  on  the  health  implications  of  that  particular  difficul- 
ty. 

So  I  have  written  a  letter  to  the  National  Institutes  of  Health,  to 
Dr.  Wyngaarden,  who  is  the  Director  of  the  NIH,  and  asked  him  to 
do  a  health  study.  My  request  for  investigation  refers  to,  and  I 
quote,  "reports  of  excessive  leukemia  in  certain  Massachusetts 
towns  downwind  from  the  Pilgrim  I  power  plant  in  Plymouth";  and 
I  have  specifically  asked  him  to  have  his  people  determine  whether 
there  is  a  causal  connection.  I  have  also  told  him  the  he  might 


91 


want  to  take  a  look  at  the  problems  at  Three  Mile  Island  as  well.  I 
have  sent  that  out  today. 

I  will  be  in  touch  personally  with  Dr.  Wyngaarden,  and  as  soon 
as  I  get  some  results  or  some  response,  I  will  share  it  with  you  and 
other  members  of  the  community. 

[The  information  referred  to  follows:] 


92 


M..WAHO  W    MII/fNMAI'U 

CMditlCtt"   I    OOOO   t 'IN 
PAIN    S>M"*<    <■  tIMOlS 
lOM  HAMKIM    >'IM* 
•  ■■()(■    AElAM^     WJkSMIMUIt 


«l>«t«<l    • 

,t»KOHD   W 

rxMOMi 

IE    iMO'M* 

iiownNO  vy 

-JTHC*"'! 

1  IN« 

1  UWWill    K 

MliCKIM    J« 

I.CUI 

fM»0  COCMlUN   MibSiSS'^**' 

r.OMXlM  J 

1    MUM»H«|» 

NEW    H»W 

iP^MtWt 

(»M 

OIHILTOK'M' 

1  '.HiF»  COtJN 

St  I 

>>    M 

iNOMilv  S'*" 

O'HtCTflR 

Bnited  States  ^tnatc 

COMMITTEE  ON  LABOR  AND 
HUMAN  RESOURCES 

WASHINGTON    DC  20510-6300 


January  7,  1987 


Dr.  James  B.  Wyngaarden,  Director 
National  Institutes  of  Health 
14  North  Drive 
Bethesda,  Maryland   20814 

Dear  Dr.  Wyngaarden: 

Over  the  past  year,  a  number  of  individuals  and  groups  have 
urged  the  Committee  to  hold  hearings  on  the  subject  of  adverse  health 
effects  of  radiation  exposure.   They  are  obviously  concerned  about 
those  dangers  in  the  context  of  potential  nuclear  power  plant 
accidents.   They  are  also  concerned  about  those  dangers  as  a 
result  of  the  possibility  of  low-level  radiation  emanating  from 
such  plants.   And,  of  course,  considerable  alarm  has  been 
expressed  with  respect  to  this  subject  as  it  relates  to  the 
accident  which  occurred  at  the  Three  Mile  Island  (TMI)  plant. 

It  has  been  my  view  that  hearings  may  be  appropriate  at- 
such  time  as  there  are  adequate  data  available,  and  when 
appropriate  scientific  inquiries  have  been  conducted.   At  that 
time,  a  comprehensive  public  airing  of  the  relevant  information, 
and  consideration  of  proposals  for  remedial  action  could  be  useful 
and  productive. 


In  view  o 
prompted  legit 
relating  to  th 
Institutes  of 
into  this  enti 
taking  address 
been  a  causal 
excesses  of  ca 
similar  report 
towns  "downwln 
Massachusetts , 
that  situation 


f  the  number  of  incidents  and  situations  which  have 
imate  concern,  and  because  of  the  dearth  of  data 
is  subject,  it  would  be  helpful  for  the  National 
Health  (NIH)  to  conduct  an  appropriate  inquiry 
re  question.   I  would  urge  that  such  an  under- 

the  question  of  whether  the  TMI  accident  has 
factor  in  what  has  been  described  as  "observed 
ncer."   In  addition,  because  there  have  been 
s  of  excesses  of  leukemia  in  certain  Massachusetts 
d"  from  the  Pilgrim  I  power  plant  in  Plymouth, 

it  would  be  helpful  to  have  your  assessment  of 

as  well. 


I  am  sure  you  are  familiar  with  the  studies  which  have 
already  been  carried  out  with  respect  to  increased  cancer  rates 
near  nuclear  test  sites  in  Nevada.   Other  studies  have  focused 
upon  radiation  exposure  in  Colorado  and  Utah.   Those  studies, 
which  have  been  sponsored  by  the  Department  of  Energy,  the 
National  Academy  of  Sciences, and  state  and  local  health 


93 


Dr.  James  B.  Wyngaarden 
PaRo  2 


departments,  have  suggested  a  possible  association  between  the 
test  sites  and  the  higher  incidence  of  cancer.   Accordingly,  it 
would  be  appropriate  for  the  NIH,  as  the  foremost  biomedical 
research  center  in  the  world,  to  address  the  question  of  whether 
a  causal  connection  does  or  does  not  exist.   And  I  would  suggest 
that  such  an  undertaking  use  as  its  first  "models"  for  evaluation 
the  TMI  and  Pilgrim  I  cases  which  I  have  described. 

You  know  of  my  continued  confidence  in  the  high  quality 
work  of  NIH.  I  look  forward  to  learning  the  results  of  your 
examination  of  this  critical  health  issue. 


Edward  M 
Chairman 


94 


DEPARTMENT  OF  HEALTH  &  HUMAN  SERVICES  Public  Health  Service 

V  National  Institutes  of  Health 

I  \  National  Cancer  Institute 

Ta  Bethesda.  Maryland  20892 

^  JIN  <  ^:  -mi 


The  Honorable  Edward  M.    Kennedy 
Ufiited  States   Senate 
Wasfiington,   D.C.   ^OSin 

Dear  Senator  Kennedy: 

I  am  pleased  to  respond  to  your  Ijtter  of  January  7,  1988  regarding  potential 
health  risks  associated  with  low-level  radiation.  Specifically,  you  raised 
concerns  about  the  health  consequences  of  nuclear  power  plant  accidents,  adverse 
effects  related  to  nuclear  power  plant  operations,  and  cancer  risks  linked  to 
radioactive  fallout  from  nuclear  weapons  testing. 

The  National  Institutes  of  Health  is  actively  involved  in  studying  the  adverse 
effects  of  ionizing  radiation,  and  we  concur  with  your  view  that  the  risks  at 
low  lavels  need  further  clarification.  We  know,  of  course,  that  radiation  can 
cause  cancer,  but  the  biological  effects  of  quite  low  levels  are  a  subject  of 
current  scientific  conjecture.  Recause  new  information  relevant  to  the 
assessment  of  low-level  risks  will  be  available  within  the  next  one  or  two 
years,  we  do  not  believe  public  '^tscussions  at  this  time  would  oe  as  fruitful  as 
they  might  be  in  the  future.  Our  reasoning  is  discussed  below. 

The  descriptive  studies  of  leukemia  clusters  around  the  Pilgrim  power  plant  in 
Massachusetts,  and  several  plants  in  the  United  Kingdom,  have  led  us  to  initiate 
a  large-scale  evaluation  of  cancer  deaths  occurring  among  persons  living  near 
the  over  100  reactors  operating  in  the  ilnited  States.  We  are  correlating  county 
mort»'ity  data  from  the  1950s  through  early  1980s  with  reactor  operations  to 
determine  whether  the  previous  reports  might  be  chance  occurr-ences  based  on 
small  numbers,  or  whether  there  might  be  valid  reasons  for  concern.  This 
evaluation  should  be  completed  within  about  one  year. 

One  of  the  major  radioactive  isotopes  emitted  during  nuclear  power  plant 
operations,  and  from  nuclear  weapons  testing,  is  iodine-131.  For  the  past  three 
years  we  have  been  collaborating  with  Swedish  colleagues  on  a  study  of  40,000 
patients  given  low  doses  of  iodine-131  for  diagnostic  reasons.  This  large  study 
will  be  finished  within  one  year  and  will  prove  invaluable  in  estimating  the 
possible  adverse  effects  from  this  environmental  contaminant.  We  have  also 
evaluated  descriptive  mortality  data  regarding  possible  cancer  risks  in  the 
general  population  living  downwind  of  the  Nevada  nuclear  test  site.  While  many 
reported  associations  are  unsupported  by  these  data,  a  small  increase  in 
leukemia  in  southwest  Utah  cannot  be  ruled  out  at  this  time.  Our  contract- 
supported  study  with  the  University  of  Utah  should  provide  more  definitive 
answers  within  the  next  year.  Finally,  staff  members  have  conducted  studies  of 
the  military  personnel  participating  at  nuclear  weapons  tests,  and  have 
confirmed  that  leukemia  was  increased  above  expectation,  but  apparently  only  for 
participants  at  one  test  series.  No  excess  -mortal ity  from  other  malignancies 
was  found  among  participants  at  any  test  series. 


95 


Page  7.   -   The  Honorable  Edward  M.  Kennedy 

The  most  serious  health  impact  of  the  Three  'lile  Island  (TMI)  accident  that  can 
be  identified  with  certainty  is  mental  stress  to  those  living  near  the  plant, 
particularly  pregnant  women  and  families  with  teenagers  and  young  children. 
Although  increased  risks  of  cancer,  birth  defects  and  genetic  abnormalities  are 
potential  long-term  consequences  of  low-level  irradiation,  few  if  any  such 
effects  are  likely.  The  average  dose  of  radiation  to  the  36,000  people  living 
within  a  five-mile  radius  of  the  plant  was  only  ?-R  mrera,  or  approximately  what 
might  be  received  from  natural  background  radiation  within  one  or  two  weeks. 
There  is  no  serious  possibility  that  this  dosage  would  result  in  any  deleterious 
effects  that  could  be  detected  epidemiologi cal ly.  (In  contrast,  at  Chernobyl  in 
the  USSR  the  average  dose  to  the  ?4,ono  people  living  near  the  reactor  was 
estimated  as  44,000  rarem.'l  The  Pennsylvania  Oepartment  of  Public  Health,  in 
consultation  with  the  Centers  for  Oisease  Control,  however,  is  conducting 
periodic  health  and  behavior  surveys  of  the  population  living  near  TMI. 
Although  psychological  effects  are  temporary  in  most  individuals,  the  ultimate 
impact  of  these  effects  remains  to  be  fully  assessed,  as  does  the  degree  to 
which  they  may  differ  from  those  caused  by  other  accidents  or  disasters.  The 
mental  stress  following  T'^I,  of  course,  has  been  aggravated  by  the  fear  that  a 
larger  release  of  radiation  might  take  place,  with  consequences  that  could  be 
disastrous  as  now  exemplified  by  the  Chernobyl  accident.  While  we  are  thankful 
that  such  an  event  has  not  occurred  in  the  United  States,  we  should  profit  from 
these  experiences  by  taking  steps  to  minimize  the  risks  of  such  accidents  in  the 
future. 

Finally,  within  two  years  the  National  Academy  of  Sciences  and  the  United 
Nations  will  complete  their  next  reports  on  the  biological  effects  of  low-level 
radiation.  We  are  also  awaiting  the  publication  of  these  scientific  documents 
before  embarking  upon  our  next  revision  of  the  Radioepidemiological  Tables 
mandated  by  Congress. 

It  is  important  to  stress  that  useful  information  about  very  small  health 
effects,  like  those  associated  with  very  low  levels  of  radiation,  is  extremely 
difficult  and  expensive  to  obtain.  An  indirect  approach,  such  as  studying 
populations  with  higher-level  exposures  and  extrapolating  the  results  to  lower 
levels,  tends  to  be  far  more  productive.  For  example,  studies  of  the  workers  at 
nuclear  power  plants  would  be  particularly  informative  because  the  doses,  though 
low,  would  be  higher  than  to  the  general  population,  and  cumulative  doses  could 
reach  levels  where  radiation  effects  might  be  detectable,  ^y  law,  radiation 
doses  ^n   recorded  on  individual  workers,  and  we  have  contacted  the  Nuclear 
Regulatory  Commission  about  the  value  of  creating  a  registry  of  the  almost 
100,000  workers  they  monitor  each  year  in  the  United  States.  Your  encouragement 
and  support  for  the  development  of  such  a  registry  would  be  invaluable  and 
greatly  appreciated. 

In  closing,  I  appreciate  your  continued  support  for  our  medical  research 
program,  and  I  will  keep  you  informed  on  developments  in  the  area  of  radiation 
studies  as  results  from  our  investigations  become  available. 

Si  ncerely , 


James  (i.  Wyngaarden,  M.O. 
Director 


■  <»^*f<  ««. 


96 

I  think  the  National  Institutes  of  Health  probably  has  as  good  a 
capability  and  capacity  to  do  that  as  any  in  the  country.  Hopefully, 
they  will  coordinate  their  work  with  the  State  officials  and  local 
officials  as  well. 

I  would  hope  that  they  would  be  able  to  call  on  much  of  the  ex- 
pertise that  we  have  heard  this  evening  and  other  expertise  as  well 
in  their  consideration. 

Let  me  ask,  because  we  want  to  move  on,  Mr.  Abbott,  about  one 
suggestion  that  has  been  made  which  is  whether  we  ought  to  have, 
create  independent  of  the  NRC,  an  independent  body  to  oversee  the 
public  health  aspects  of  nuclear  plant  radiation  releases.  I  don't 
know  if  you  have  any  opinions  about  that.  I  don't  know  quite  how 
we  would  set  it  up. 

Mr.  Abbott.  Well,  Mr.  Chairman,  there  is  a  definite  perception 
of  the  public  that  the  NRC  is  still  promoting  nuclear  power,  rather 
then  being  most  concerned  about  the  health  and  effect  of  nuclear 
power. 

I  think  part  of  what  I  was  trying  to  express  was  that  the  percep- 
tion of  the  public  was  that  really  nothing  was  being  done  to  protect 
it,  and  I  don't  think  we  have  any  comfort  level  that  the  NEC  is 
doing  it.  Whether — I  have  pleadings  to  the  State  of  Massachusetts 
to  have  another  Federal  agency  which  is  to  be  kept  totally  inde- 
pendent of  the  promotion  of  nuclear  power;  then  that  might  do  the 
job. 

The  Chairman.  I  noted  your  testimony,  Mary  Ott,  with  regards 
to  the  difficulties  that  you  had  in  getting  information,  having  to 
run  through  the  Freedom  of  Information  Act  to  get  that,  that  is 
obviously  enormously  discouraging.  I  don't  know  whether  you  have 
any  reaction  to  some  independent  health  advisory  group  to  monitor 
these  types  of  activities. 

Of  course,  we  would  have  to  decide  who  appoints  it;  who  it  is  ac- 
countable to,  and  whether  we  are  just  creating  more  bureaucracy, 
but  maybe  you  can  give  some  thought  to  it.  We  might  try  to  circu- 
late some  suggestions  along  those  lines  and  try  to  get  some  of  your 
reaction  to  them. 

And,  Anne,  I'm  still  troubled  by  your  report  in  terms  of  how  any 
evacuation  plan  is  going  to  have  to  deal  with  some  of  those  who 
have  physical  or  mental  limitations.  You,  as  I  understand,  have 
made  those  representations  to  FEMA,  have  you? 

Ms.  Waitkus-Arnold.  FEMA,  yes. 

The  Chairman.  And  I  understand  that  one  of  the  major  conclu- 
sions FEMA  reached  when  they  withdrew  their  approval  was  that 
the  evacuation  plan  contained  inadequate  planning  for  the  evacu- 
ation of  the  special  needs  population. 

Ms.  Waitkus-Arnold.  Right. 

The  Chairman.  And  I  think  you  should  take  some  sense  of  satis- 
faction that  someone  at  least  listened  to  what,  I  think,  is  really  one 
of  the  most  provocative,  unbelievable  things  that  I've  heard  in  pre- 
paring for  the  hearing.  I  must  say  I  was  absolutely  dumbfounded.  I 
should  probably  have  known  about  it,  but  I  think  it  must  have 
stirred  the  heart  and  soul  of  any  citizen  to  think  that  that's  the 
way  we're  going  to  treat  our  fellow  citizens,  particularly  those  who 
are  facing  some  physical  challenge. 


97 

I  want  to  thank  all  of  you  very  much.  You  have  been  extremely 
helpful.  I  think  the  questions  that  you  have  raised  have  enormous 
potential  impact  for  the  people  living  in  the  area  and  throughout 
the  state.  We're  very  grateful  to  all  of  you  for  your  hard  work.  It  is 
quite  clear  from  your  testimony  and  from  your  fuller  statements 
the  amount  of  time  and  the  expertise  that  you  have  put  into  this 
consideration,  not  only  yourselves,  but  with  your  fellow  citizens.  It 
is  really  citizenship  at  its  very  best. 

I'm  grateful  to  you,  and  I  will  take  the  liberty,  when  I  talk  to  Dr. 
Wyngaarden,  to  mention  each  of  you,  and  to  send  along  your  testi- 
monies, and,  hopefully,  NIH  will  have  your  input  when  they  do 
their  work.  I  want  to  thank  all  of  you  for  your  presentations. 
Thank  you  very  much. 

[Applause.] 

The  Chairman.  Our  next  panel  is  comprised  of  some  representa- 
tives and  public  officials  who  represent  people  who  live  in  this 
area,  and  also  the  representative  of  one  of  our  foremost  public  in- 
terest organizations.  All  of  these  witnesses  have  worked  long  and 
hard  on  Pilgrim  I  questions.  I  welcome  them  here  this  evening  to 
share  with  the  committee  their  judgments  and  concerns. 

First,  we  have  Senator  Bill  Golden,  who  I'm  sure  is  no  stranger 
to  any  of  you  nor  to  me.  Bill  has  been  unrelenting  in  his  attention 
to  Pilgrim  and  I  look  forward  to  his  testimony. 

We'll  also  hear  from  State  Representative  Larry  Alexander,  who 
has  previously  testified  before  Congress  on  Pilgrim.  Peter  Forman, 
State  Representative  from  Plymouth,  who  led  a  state  legislative 
committee  effort  on  the  subject  of  Pilgrim;  David  Malaguti,  who  is 
the  chairman  of  the  Plymouth  Board  of  Selectmen,  and  who  has 
devoted  a  lot  of  time  on  the  issue;  and  Ms.  Rachel  Shimshak,  from 
the  Massachusetts  Public  Interest  Research  Group,  an  organization 
which  over  the  last  several  years  has  issued  three  major  reports 
dealing  with  the  Pilgrim  I  plant. 

I  welcome  all  of  you  here  and  look  forward  to  your  presentations. 
Why  don't  we  go  left  to  right.  Three  minutes  each. 

STATEMENTS  OF  LAWRENCE  ALEXANDER,  STATE  REPRESENTA- 
TIVE;  PETER  FORMAN,  STATE  REPRESENTATIVE;  DAVID  MALA- 
GUTI, CHAIRMAN  OF  THE  PLYMOUTH  BOARD  OF  SELECTMEN; 
AND  RACHEL  SHIMSHAK,  MASSACHUSETTS  PUBLIC  INTEREST 
RESEARCH  GROUP 

Mr.  Alexander.  Thank  you,  Senator.  I  also  would  like  to  thank 
you  for  this  opportunity,  and  I  have  some  additional  materials 
which  I  would  like  to  offer  to  your  committee,  as  an  appendix, 
along  with  copies  of  my  testimony. 

As  chairman — house  chairman  of  the  Massachusetts  Legisla- 
ture's Joint  Committee  on  Energy 

The  Chairman.  Wait  a  second.  I  forgot  to  swear  you  in. 

[Applause.] 

[Witnesses  sworn.] 

Mr.  Alexander.  Well,  if  that's  the  case,  let  me  change  my 
speech.  [Laughter.] 

Just  kidding. 


98 

Senator,  I  testify  today  with  great  appreciation  for  your  concern 
about  this  very  important  subject.  I'm  State  Representative  Larry 
Alexander.  I'm  house  chairman  of  the  Legislature's  Joint  Commit- 
tee on  Energy,  and  I  believe  that  there  are  two  significant  issues 
associated  with  nuclear  power  that  warrant  major  Federal  investi- 
gations immediately. 

First,  Congress  should  order  an  in-depth,  nationwide  analysis  of 
whether  people  suffer  adverse  health  consequences  as  a  result  of 
living  near  nuclear  powerplants.  I  was  delighted  to  hear  about  your 
request  to  the  National  Institute  of  Health  in  that  regard. 

Second,  I  believe  that  Congress  should  order  an  intense  investiga- 
tion of  the  safety  systems  that  operators  of  European  nuclear  reac- 
tors have  added  to  their  nuclear  powerplants  to  determine  whether 
operators  of  American  nuclear  powerplants  should  make  similar 
modifications. 

Let  me  discuss  each  of  these  two  issues  in  a  little  more  detail. 
First  of  all,  with  respect  to  the  health  effects  of  living  near  nuclear 
reactors,  there  is  an  increasing  body  of  scientific  evidence  that 
seems  to  suggest  that  routine  and  accidental  releases  of  radiation 
from  nuclear  reactors  may  be  causing  increased  leukemia,  cancer, 
infant  mortality,  congenital  defects  and  other  adverse  conse- 
quences. 

For  that  reason,  I  filed  a  bill  to  have  Massachusetts  set  its  own 
standards  for  radioactive  emissions  from  nuclear  powerplants, 
which  it  is  allowed  to  do  under  federal  law.  I'm  pleased  to  say  the 
bill  passed  the  House,  but  it  has  failed  to  pass  the  Senate  yet,  but  I 
hope  that  ultimately,  we'll  be  able  to  pass  that  law. 

The  Massachusetts  Department  of  Public  Health  has  found  sta- 
tistically significant  increased  incidences  of  leukemia  in  communi- 
ties near  the  Pilgrim  reactor.  There  was  a  59-percent  increase  in 
blood  disorders,  including  leukemia,  for  Plymouth,  Kingston,  Dux- 
bury,  Marshfleld,  and  Scituate  for  the  years  1982  through  1984.  In 
1985,  there  were  three  times  as  many  cases  of  these  blood  disorders 
than  would  normally  be  expected  for  women  in  Plymouth — six 
cases  instead  of  two — and  the  total  increase  for  the  five  towns  from 
1982  through  1985  was  a  statistically  significant  43  percent. 

Dr.  Sidney  Cobb,  whom  you  alluded  to  earlier,  found  that  there 
seemed  to  be  an  increase  in  infant  mortality  and  congenital  defect 
rates  that  took  place  in  coastal  communities  adjacent  to  or  north  of 
Plymouth  soon  after  significant  radioactive  emissions  were  dis- 
charged from  Pilgrim  in  the  1970's. 

There  also  seems  to  be  some  evidence  of  perhaps  increased  leuke- 
mia for  people  living  downwind  from  Maine  and  Connecticut  reac- 
tors. And  there  was  a  recent  study  in  Lancet  magazine  suggesting 
a  possible  correlation  between  proximity  to  nuclear  power  plants 
and  increased  leukemia  incidences  in  England. 

Therefore,  I  hope  that  Congress  will  do  a  major  analysis  of  this 
issue  on  a  nationwide  basis  to  put  this  issue  to  rest  one  way  or  the 
other  for  citizens  who  live  near  those  nuclear  powerplants. 

Let  me  turn  now  briefly  to  the  issue  of  nuclear  reactor  safety, 
particularly  with  reference  to  the  General  Electric  Mark  I  reactor 
found  at  Pilgrim.  I  have  serious  doubts  about  the  adequacy  of  the 
containment  structure  at  Pilgrim. 


99 

Many  European  reactors  have  safety  features  that  American  re- 
actors don't  have.  Some,  for  instance,  have  a  filtered  vent  to  pre- 
vent overpressurization  and  a  consequent  breach  of  containment. 
The  filters  trap  most  of  the  radiation. 

My  understanding  is  that  Boston  Edison  does  not  plan  to  put  any 
filters  in  the  vents  that  it  is  going  to  put  in  at  the  Pilgrim  plant.  I 
find  that  strange.  Even  the  owners  of  the  Shoreham  reactor  in 
Long  Island  have  announced  their  intention  to  install  a  filtered 
vent,  and  I  fail  to  see  why  the  Pilgrim  owners  do  not  plan  to  do  so 
as  well. 

Many  European  reactors  also  have  an  additional,  independent 
decay  heat  removal  system  that  serves  as  a  type  of  backup  cooling 
system  in  case  of  failure  of  the  original  residual  heat  or  emergency 
core  cooling  system.  Some  of  the  European  systems  have  done  that, 
and  yet  Boston  Edison  has  not  seen  fit  to  install  this  system  here. 
If  it's  good  enough  for  some  of  the  European  plants,  I  wonder  why 
it  is  not  good  enough  to  have  here. 

A  federal  investigation,  preferably  independent  of  the  NRC, 
should  be  undertaken  immediately  of  the  filtered  vent,  the  bun- 
kered RHR  system,  and  other  European  safety  systems  to  deter- 
mine whether  they  should  be  added  to  American  nuclear  power- 
plants. 

Congress  should  also  consider  requiring  construction  of  a  second 
steel-reinforced  concrete  containment  structure  and  molten  core 
barriers  before  General  Electric  Mark  I-designed  plants,  such  as 
Pilgrim,  are  allowed  to  continue  to  operate.  Pilgrim  should  also  not 
be  allowed  to  restart  unless  the  Governor  reaches  a  threshold  de- 
termination that  an  evacuation  plan  can  adequately  protect  public 
health  and  safety,  and  local  officials  and  the  Governor  have  ap- 
proved such  a  plan. 

Let  me  add  one  final  word  with  regard  to  Pilgrim.  I  am  becoming 
more  and  more  convinced  that  we  may  not  need  the  power  from 
Pilgrim. 

Boston  Edison's  own  forecast  of  electric  supply  and  demand 
shows  that  it  probably  won't  need  Pilgrim  power  from  1990  to  the 
year  2000.  With  conservation  and  energy  produced  by  small-power 
facilities,  we  may  not  need  electricity  from  Pilgrim. 

So,  therefore,  all  of  us  should  ask  ourselves  why  we  should  take  a 
risk  that  we  don't  have  to  take.  All  of  us  should  ask  ourselves  the 
ultiniate  question,  do  we  really  need  to  take  the  risk  of  Pilgrim  re- 
opening when  we  may  not  even  need  the  power  it  might  produce? 

[Applause.] 

Thank  you  very  much. 

[The  prepared  statement  of  Mr.  Alexander  follows:] 


100 


LAWRENCE  R.  ALEXANDER 

REPRESENTATIVE 

exM   ESSEX   DISTRICT 

5-*   LONGVIEW   DRIVE 

MARBLEHEAO     MA  OI919 

TEL    631.7646 


ADM 


iiSTRATivE   Assistant 
MELISSA   eURKE 


HOUSE  OF  re:pre:sentatives 

STATE    HOUSE.    BOSTON    02133 


Charrman 
Commtllee  on  Energy 

ROOM  640    STATE  HOUSE 
Teu  722-2090 

Research  Director 
MICHAEL  ERNST 


TESTIMONY  OF  STATE  REPRESENTATIVE  LAWRENCE  R.  ALEXANDER, 

HOUSE  CHAIRMAN  OF  THE  MASSACHUSETTS  LEGISLATURE'S  JOINT  COMMITTEE  ON  ENERGY, 

BEFORE  THE  LABOR  AND  HUMAN  RESOURCES  COMMITTEE  OF  THE  UNITED  STATES  SENATE 

JANUARY  7,  1988 


I  would  like  to  thank  you,  Mr.  Chairman,  and  the  members  of  this  committee, 
for  your  deep  concern  over  this  issue  and  for  holding  this  important  hearing 
here  in  Massachusetts  so  that  you  can  hear  directly  from  the  citizens  who 
are  most  affected  by  the  Pilgrim  nuclear  power  plant. 

As  House  Chairman  of  the  Joint  Committee  on  Energy  of  the  Massachusetts 
Legislature,  I  believe  there  are  two  significant  issues  associated  with  nuclear 
power  that  warrant  major  federal  investigations  immediately. 

First,  Congress  should  order  an  in-depth  nationwide  analysis  of  whether 
people  suffer  adverse  health  consequences  as  a  result  of  living  near  nuclear 
power  plants. 

Second,  Congress  should  order  an  intense  investigation  of  the  safety 
systems  that  operators  of  European  nuclear  reactors  have  added  to  their  nuclear 
power  plants,  to  determine  whether  operators  of  American  nuclear  power  plants 
should  make  similar  modifications. 

Let  me  discuss  each  of  these  matters  in  more  detail. 

With  respect  to  the  health  effects  of  living  near  nuclear  reactors,  there 
it  an  increasing  body  of  scientific  evidence  that  seems  to  suggest  that  routine 


101 


and  accidental  releases  of  radiacton  from  nuclear  reactors  may  be  causing 
increased  leukemia,  cancer,  infant  mortality,  congenital  defects  and  other 
adverse  consequences. 

The  Massachusetts  Department  of  Public  Health  has  found  a  statistically 
significant  increased  incidence  of  leukemias  in  communities  near  the  Pilgrim 
reactor.    There  was  a  59  percent  increase  in  blood  disorders  including  leukemias 
for  Plymouth,  Kingston,  Duxbury,  Marshfield  and  Scituate  for  the  years  1982 
through  1984.   In  1985,  there  were  three  times  as  many  cases  of  these  blood 
disorders  than  would  normally  be  expected  for  women  in  Plymouth  (6  cases  instead 
of  2),  and  the  total  increase  for  the  five  towns  from  1982  through  1985  was 
a  statistically  significant  43  percent. 

Dr.  Sidney  Cobb,  the  distinguished  epidemiologist  who  originally  identified 
this  increase  in  leukemias,  has  also  found  that  an  increase  in  infant  mortality 
and  congenital  defect  rates  took  place  in  coastal  communities  adjacent  to 

or  north  of  Plymouth  soon  after  significant  radioactive  emissions  were  discharged 

2 
from  Pilgrim  in  the  1970's.    Evidence  also  seems  to  suggest  some  increased 

3 
leukemias  for  people  living  downwind  from  Maine  and  Connecticut  reactors. 

Dr.  Bailus  Walker,  President  of  the  American  Public  Health  Association,  and 

a  former  Massachusetts  Commissioner  of  Public  Health,  has  recommended  a  regional 

analysis  of  the  health  consequences  of  living  near  nuclear  reactors. 

Dr.  Jay  Gould  recently  released  a  national  study  revealing  higher  infant 

4 
and  fetal  mortality  rates  in  counties  close  to  boiling  water  reactors.    He 

believes  that  emissions  from  nuclear  reactors  are  associated  with  nearly  9,000 

5 
excess  deaths  each  year. 

The  United  States  is  not  the  only  country  in  which  studies  show  possible 

adverse  health  consequences  for  people  living  near  nuclear  power  plants. 

A  1987  study  in  Lancet  magazine  suggests  a  significant  correlation  between 

proximity  to  nuclear  power  plants  and  increased  leukemia  incidence  in  England. 


102 


Other  studies  also  suggest  a  need  for  further  investigation. 

While  it  is  very  difficult  to  prove  a  definite  causal  link  between  the 
50  million  curies  of  radioactive  emissions  released  from  American  nuclear 
reactors  and  the  specific  adverse  health  effects  that  people  have  suffered, 
the  growing  body  of  epidemiological  evidence  suggesting  the  possibility  of 
such  a  link  makes  it  imperative  that  we  explore  this  issue  in  more  detail. 
The  only  way  to  do  this  thoroughly  is  for  Congress  to  order  a  comprehensive 
nationwide  epidemiological  study  of  this  matter  immediately. 

Let  me  now  turn  to  the  issue  of  nuclear  reactor  safety,  particularly 
with  reference  to  the  General  Electric  Mark  I  reactor  found  at  Pilgrim.   I 
have  serious  doubts  about  the  adequacy  of  the  containment  structure  at  Pilgrim. 

Former  NRC  Commissioner  James  Asselstine  has  stated,  "America  can  expect 
to  see  a  core  meltdown  accident  within  the  next  20  years,  and  it  is  possible 
that  such  an  accident  could  result  in  off-site  releases  of  radiation  which 
are  as  large  as,  or  larger  than,  the  releases  estimated  to  have  occurred  at 

o 

Chernobyl."   American  reactors,  he  notes,  "were  not  designed  to  withstand 

9 
large-scale  core  meltdowns." 

Many  European  reactors,  on  the  other  hand,  have  safety  features  that 
American  reactors  do  not  have.   Some,  for  instance,  have  a  filtered  vent  to 
prevent  overpressurization  and  a  consequent  breach  of  containment.     Their 
filters  trap  most  of  the  radiation.   The  owners  of  the  Shoreham  reactor  in 
Long  Island  have  announced  their  intention  to  install  such  a  filtered  vent. 
Pilgrim  should  not  restart  until  and  unless  Pilgrim  has  such  a  filtered  vent. 

Many  European  reactors  have  an  additional,  independent  decay  heat  removal 
system  that  serves  as  a  back-up  cooling  system  in  case  of  failure  of  the  original 
residual  heat  removal  (RHR)  system  and  of  the  emergency  core  cooling  system. 
This  back-up  system  is  also  independently  powered  in  case  of  station  blackout 
and  is  "bunkered"  underground  to  protect  against  earthquake  damage  and  sabotage. 


103 


S«iss  authorities  have  started  retrofitting  some  Swiss  reactors  with  this 
system,  including  an  older  boiling  water  reactor. 

The  Pilgrim  reactor  was  shut  down  in  1986  due  to  failures  of  the  RHR 
system.   It  does  not  have  a  back-up,  bunkered  RHR  system.   If  Europeans  are 
installing  additional  cooling  systems  in  their  boiling  water  reactors,  why 
shouldn't  Boston  Edison  install  the  same  system  to  provide  more  protection 
against  meltdowns  at  the  Pilgrim  reactor?   Boston  Edison  should  install  a 
bunkered  RHR  system  at  Pilgrim  before  restart. 

A  federal  investigat ion--preferably  independent  of  the  NRC--should  be 
undertaken  immediately  of  the  filtered  vent,  the  bunkered  RHR  system,  and 
other  European  safety  systems  to  determine  whether  they  should  be  added  to 
American  nuclear  power  plants.   Congress  should  also  consider  requiring  construction 
of  a  second  steel-reinforced  concrete  containment  structure  and  molten  core 
barriers  before  General  Electric  Mark  I-designed  plants  such  as  Pilgrim  are 
allowed  to  continue  to  operate.   Pilgrim  should  also  not  be  allowed  to  re-start 
unless  the  Governor  reaches  a  threshold  determination  that  an  evacuation  plan 
can  adequately  protect  public  health  and  safety,  and  local  officials  and  the 
Governor  have  approved  such  a  plan. 

Let  me  add  one  final  word  with  regard  to  Pilgrim.   I  am  becoming  more 
and  more  convinced  that  we  may  not  need  the  power  from  Pilgrim.   Boston  Edison's 

own  forecast  of  electric  supply  and  demand  shows  that  it  probably  won't  need 

12 
Pilgrim  power  from  1990  to  2000.     With  conservation  and  energy  produced 

by  small-power  facilities,  we  may  not  need  electricity  from  Pilgrim. 

All  of  us  should  ask  ourselves  why  we  should  take  a  risk  that  we  don't 
have  to  take.   All  of  us  should  ask  ourselves  Che  ultimate  question--do  we 
really  need  to  take  the  risk  of  Pilgrim  re-opening  when  we  may  not  even  need 
the  power  it  might  produce? 

Thank  you  very  much. 


104 


FOOTNOTES 

1.  "Health  Surveillance  of  Che  Plymouth  Area,"  Mass.  Department  of  Public 

Health,  March  16,  1987.   (Appendix  A) 

2.  "Testimony  of  Sidney  Cobb,  M.D.,"  presented  to  the  Joint  Committee  on  Energy, 

March  24,  1987.   (Appendix  B) 

3.  Ibid. 

4.  "Nuclear  Emissions  Take  Their  Toll;"  Gould,  J.M.  et  al;  Council  on  Economic 

Priorities  Publication  N86-12;  December,  1986,  p.  7.   (Appendix  C) 

5.  Ibid.,  p.  9. 

6.  "Cancer  Near  Nuclear  Installation,"  Beral,  V.,  Lancet,  March  7,  1987,  p. 

556.   (Appendix  D) 

7.  Bibliography  of  over  100  relevant  research  papers.   (Appendix  E) 

8   "Testimony  of  Commissioner  James  K.  Asselstine,  U.S.  N.R.C.,  before  the 

Subcommittee  on  Energy  Conservation  and  Power  of  the  Committee  on  Energy 
and  Commerce,"  May  22,  1986,  p.  3.   (Appendix  F) 

9.  Ibid. 

10.  "International  Nuclear  Reactor  Hazard  Study,"  Anderson,  R.  et  al.  Volume 

II,  September,  1986;  v,  ,  .. 

"Europeans  Head  Toward  Filtered  Vented  Containments  after  Chernobyl, 
Nucleonics  Week,  June  12,  1986. 

11  "Muehleberg  Begins  Backfit  for  Bunkered  Emergency  Cooling  System,"   Nucleonics 

Week   November  13,  1986.   Telephone  conversations  between  staff  of  Commissioner 
:KIi^lstine,  November,  1986,  and  staff  of  Joint  Committee  on  Energy. 

12  "Conservation  and  Load  Management,"  Boston  Edison,  Exhibit  V-1  ("Boston 

Edison's  Long  Range  Resource  Plan:"  Between  1990-2000,  Boston  Edison 

will  have  more  than  500  MW  of  capacity  beyond  its  reserve  capacity  needs-Boston 

Edison  receives  less  than  500  MW  of  capacity  from  Pilgrim),  submitted 

to  the  Department  of  Public  Utilities  in  November,  1987.   (Appendix  G) 


105 

The  Chairman.  Provocative.  [Laughter.] 

Representative  Forman. 

Mr.  Forman.  Thank  you,  Senator.  My  name  is  Peter  Forman. 
I'm  the  State  representative  for  Plymouth  and  Kingston;  I'm  a  resi- 
dent of  Plymouth.  I  recently  served  as  house  chairman  of  the  legis- 
lature's Joint  Special  Committee  to  investigate  the  plant. 

I  want  to  congratulate  you  for  this  hearing.  While  many  state 
and  local  officials  have  been  quite  vocal  and  active  trying  to  keep 
pressure  on  the  NRC,  it  is  obvious  that  there  is  little  state  or  local 
jurisdiction  over  nuclear  plants,  and  is  almost  exclusively  under 
Federal  control.  As  such,  we  are  very  pleased  that  you  have  taken 
this  initiative. 

I  understood  from  your  staff  that  the  focus  of  the  hearing  was 
not  so  much  on  Edison's  performance,  rather  the  performance  of 
the  federal  agency,  particularly  the  NRC,  who  regulates  the  utili- 
ties. So  I  would  like  to  offer  a  few  broad  observations  about  the 
NRC's  work. 

One  of  the  most  commonly  heard  criticisms  is  that  the  NRC  is 
too  much  an  advocate  to  nuclear  power  and  not  a  watchdog.  I 
would  like  to  give  you  two  examples  of  how  I  think  some  of  the 
NRC's  thinking  is  oriented  to  keeping  the  plants  open. 

The  first  is  the  lack  of  decommissioning  plans.  In  the  many 
meetings  held,  we  have  come  away  with  a  sense  that  one  reason 
NRC  is  reluctant  to  close  any  plant  is  because  nobody  seems  to 
know  what  to  do  with  the  plant  once  it  is  closed.  That  sort  of  per- 
petuates an  interest  in  making  sure  that  they  are  open  so  those 
very  tough  questions  don't  have  to  be  addressed  immediately. 

I  would  urge,  as  a  previous  witness  has,  that  Congress  and  the 
Administration  not  allow  any  delay  in  selecting  a  Federal  disposal 
site  because  I  think  that's  one  of  the  reasons  we  don't  want  to  ad- 
dress the  issue  of  decommissioning. 

In  the  meantime,  though,  I  think  everyone  would  be  well  served 
with  decommissioning  plans  for  power  plants,  including  Pilgrim, 
and  I  would  like  to  urge  the  NRC  and  Boston  Edison,  along  with 
any  State,  Federal,  and  local  officials  to  begin  planning  for  decom- 
missioning, so  area  residents  and  ratepayers  and  State  officials  will 
know  what's  in  store  for  us  when  a  plant  is  permanently  closed. 

The  second  example  of  NRC  gravitation  toward  keeping  plants 
open  is  their  grading  system  of  plants'  performance.  We're  all  fa- 
miliar with  the  SALP  reports  and  their  three  performance  ratings. 
None  of  these  rating  categories  include  failures  or  fail  rates.  There 
are  no  objective  criteria  or  performance  ratings  that  would  trigger 
a  license  revocation  or  a  review  of  licensee  performance.  I  think 
that  the  public  and  nuclear  industry  need  to  see  clear  standards  as 
to  exactly  what  constitutes  a  poorly  run  or  a  failing  plant. 

The  issues  surrounding  public  health  are,  of  course,  paramount, 
but  I  get  the  sense  that  the  NRC  works  in  short-term,  incident  spe- 
cific reviews  of  whether  or  not  a  plant  is  responsible  for  any  threat 
to  public  health.  I  would  urge  the  Congress,  or  an  agency  other 
than  the  NRC,  begin  some  sort  of  comprehensive,  long-term  studies 
to  the  public  health  impact,  if  any,  around  nuclear  powerplants. 
These  studies  should  include  the  exposure  to  health  histories,  as 
well  as  the  cumulative  exposure  to  the  general  public. 


106 

I  would  like  to  make  another  general  observation  about  work 
place  safety  not  related  to  radiation  exposure.  Not  too  long  ago, 
Edison  had  a  project  to  remove  asbestos  from  the  plant.  One  of  the 
plant  employees  suggested  to  me  that  the  work  was  poorly  done 
and  that  there  was  unnecessary  risks  of  asbestos  exposure  to  the 
employees  in  the  area.  Questions  were  raised  about  as  OSHA's  abil- 
ity to  supervise  or  investigate  this  problem.  And  I  think  some  work 
needs  to  be  done  to  insure  that  the  NRC  regulations  and  the  indus- 
try standard  to  reduce  radiation  exposure,  as  well  as  NRC's  almost 
exclusive  jurisdiction  over  nuclear  plants,  does  not  reduce  nonra- 
diation  related  workplace  safety  standards. 

On  another  matter,  questions  have  been  raised  about  the  rela- 
tionship with  contract  workers  in  the  plant;  who  do  they  answer  to, 
what  kind  of  quality  control  is  achieved  and  how  well  do  they  work 
with  other  employees,  and  understand  the  NRC  regulations.  I 
would  hope  that  the  NRC  will  conduct  some  sort  of  fuller  investiga- 
tion into  those  questions. 

As  house  chairman  of  the  Joint  Special  Legislative  Committee 
dealing  with  Pilgrim,  there  were  two  matters  that  we  simply  were 
not  able  to  resolve.  One  was  the  issue  of  Mark  I  designs.  Is  there, 
in  fact,  an  increase  of  containment  failure  in  a  Mark  I  design?  Do 
these  higher  risks,  if  any,  compensate  for  some  other  measures? 

The  other  is  over  charges  of  past  releases.  And  Mr.  Abbott,  I 
think,  has  probably  done  the  best  job  in  documenting  one  such  re- 
lease in  1982. 

Should  the  NRC  refuse  an  adjudicatory  hearing  on  Pilgrim's  li- 
cense, then,  at  least  I  hope  the  NRC,  or  your  committee,  would 
have  some  sort  of  hearings  on  these  two  issues  because  these  are  of 
critical  concern  to  the  area  residents,  and  we  simply  do  not  have 
the  resource  in  our  State  legislature  to  begin  sorting  out  the  issues 
of  past  releases  or  the  Mark  I  containment  issue. 

Finally,  I  would  like  to  very  quickly  touch  on  the  issue  of  emer- 
gency preparedness.  The  NRC  has  created  what,  I  think,  is  a  real 
jurisdictional  mess  over  the  issue  of  emergency  preparedness.  By 
requiring  local  approval  of  plans,  the  NRC  may  or  may  not  have 
given  States  the  power  to  close  plants.  How  far  this  power  actually 
goes  is  unclear,  but  I  think  it  is  in  everyone's  interest  that  it  needs 
to  be  clarified,  clarified  preferably  by  Congress,  not  the  NRC.  This 
should  be  done  as  soon  as  possible,  so  that  state  officials  will  have 
some  sense  as  to  how  much  power,  if  any,  state  and  local  officials 
have  in  closing  a  plant  and  preventing  a  plant  like  Pilgrim  from 
coming  back  on  line  or  preventing  one  from  opening  up  through 
the  use  of  the  emergency  preparedness  plans. 

Again,  Senator,  let  me  congratulate  you  for  focusing  some  con- 
gressional attention  on  this,  and  particularly  on  the  NRC  and  its 
role  as  a  federal  regulator. 

[The  prepared  statement  of  Mr.  Forman  follows:] 


107 


TESTIMONY  OFFERED  BY 

STATE  REPRESENTATIVE  PETER  FORMAN 

BEFORE  THE  SENATE  COMMITTEE  ON  LABOR  AND  HUMAN  RESOURCES 

JANUARY  6,  1988 


108 


Wi^t  Cotranottfoeallif  nf  ,i3!lassacI{U2ctts 

^iouse  of  ^eptfsentniib^ 
,^tat£  ^mise,  Boston  02133 


PETER   FORMAN 

1ST  PLYMOUTH   DISTRICT 

1     MT     PLEASANT    ST 

PLYMOUTH     MA  02360 

TEL.   746-0344 

ROOM  40,   STATE  HOUSE 
TEL.   722-2240 


Commiltees  on 

Health  Care 

Insurance 

Special  Commilteei  on 

Reapporiionmenl 

Pilgrim  Nuclear  Power  Planr 

MARGARET   GARDNER 
LEGISLATIVE   ASSISTANT 


Senator  Kennedy: 

My  name  is  Peter  Forman .  I  am  the  State  Representative 
for  Plymouth  and  Kingston  and  a  resident  of  Plymouth. 
Recently,  I  served  as  House  Chairman  of  the  Legislature's 
Joint  Special  Committee  to  Investigate  the  Pilgrim  Nuclear 
Power  Plant. 

Let  me  congratulate  you  for  this  hearing.  While  state 
and  local  officials  have  been  quite  vocal  and  active  in 
keeping  pressure  on  Edison  and  the  NRG,  it  is  obvious  that 
there  is  little  state  or  local  jurisdiction  over  nuclear 
plants.  This  is  a  matter  of  almost  exclusive  federal  control 
and  as  such  we  are  pleased  to  see  Congressional  attention 
being  focused  on  this  issue. 

I  understand  from  your  staff  that  the  intent  of  this 
hearing  is  not  so  much  to  review  Pilgrim's  history  or  to 
investigate  the  work  Pilgrim  has  been  doing.  Rather,  it 
is  to  review  the  performance  of  the  federal  agencies, 
specifically  the  NRC ,  in  regulating  Pilgrim. 

One  of  the  most  commonly  heard  criticisms  is  that  the 


r^ ..  „..  .  1  , 


109 


enough  of  a  watchdog.  Let  me  give  you  two  examples  of  how 
NRC  thinking  is  oriented  to  keeping  plants  open.  One  is 
the  lack  of  de-commissioning  plans. 

From  the  many  meetings  held  on  Pilgrim,  I  have  come 
away  with  a  sense  that  one  reason  NRC  is  reluctant  to  close 
plants  is  because  nobody  seems  to  know  what  to  do  with  a 
plant  once  it  has  been  closed.  Clearly,  part  of  the  problem 
is  the  lack  of  a  permanent  disposal  or  storage  site  for 
the  high-level  waste.  This  issue  needs  to  be  addressed 
and  I  hope  that  neither  the  Congress  nor  adminisitration 
will  allow  any  further  delays  on  selecting  a  federal  site. 

In  the  meantime,  though,  everyone  would  be  well  served 
to  have  decommissioning  plans  for  power  plants.  I  would 
like  to  urge  the  NRC  and  Boston  Edison,  along  with  state 
and  local  officials,  to  begin  planning  for  decommissioning. 
Area  residents  should  know  what  will  be  done  with  a 
permanently  closed  site.  Likewise,  the  state  and  utility 
ratepayers  should  know  the  expected  cost  of  decommissioning. 

The  second  example  is  of  NRC  grading  of  plant 
performance.  As  we  have  seen  in  the  SALP  reports,  there 
are  three  performance  ratings.  None  of  the  three  is  a  failing 
grade.  There  are  no  objective  criteria  on  performance  that 
would  trigger  a  license  revocation  or  hearing  to  review 
licensee  performance.  The  public  and  nuclear  industry  need 
to  see  clearer  standards  as  to  what  constitutes  a  poorly 
run  or  failing  plant. 


no 


The   issues   surrounding  public  health  are,   of  course, 

the  greatest  concern.   However,   the  NRC  seems  to  work   in 

short-term,  incident-specific  reviews  of  whether  or  not 
a  plant  is  responsible  for  a  threat  to  public  health. 

The  Congress,  through  an  agency  other  than  NRC,  should 
begin  comprehensive,  long-term  studies  of  the  public  health 
impacts,  if  any,  of  nuclear  power  plants.  These  studies 
should  include  employee  exposure  and  health  histories,  as 
well  as  cummulative  exposure  risks  to  the  general  public. 

As  you  know,  there  has  been  an  above-average  occurence 
of  certain  cancers  in  the  South  Shore  area.  The  State 
Department  of  Public  Health  is  conducting  a  long  overdue 
study. 

Frankly,  I  doubt  there  will  be  any  definite  conclusion  as 
to  the  possible  causes  of  this  slight  elevation  -  if  in 
fact  there  is  a  cause.  However,  it  would  have  been  useful 
to  have  had  long-term  studies  around  other  plants  to  see 
if  there  were  common  events,  or  what  the  history  has  been 
around  other  plants. 

Let  me  make  another  observation  about  general  workplace 
safety.  Not  too  long  ago,  Edison  had  a  project  to  remove 
asbestos  from  the  plant.  An  employee  has  suggested  to  me 
that  the  work  was  poorly  done  and  there  were  unnecessary 


Ill 


risks  of  asbestos  exposure.  Quescions  were  raised  about 
OSHA's  ability  to  supervise  and  investigate  this  work.  I 
think  some  work  needs  to  be  done  to  ensure  that  NCR 
regulations,  the  strict  standards  to  reduce  radiation 
exposure,  and  NRC ' s  almost  exclusive  jurisdiction  over  nuclear 
plants  does  not  reduce  non-radiation  work  place  safety 
standards . 

On  another  matter,  questions  have  been  raised  about 
the  relationship  of  contract  workers  in  a  plant.  Who  do 
they  answer  to?  What  kind  of  quality  control  is  achieved? 
How  well  do  contract  workers  work  with  regular  employees? 
How  well  do  contract  workers  understand  and  follow  NRC 
regualtions?  These  are  matters  which  I  have  not  seen  fully 
studied  . 

There  were  two  important  matters  in  the  Special 
Committee's  work  which  we  simply  were  unable  to  resolve. 
One  was  the  issue  of  Mark  I  designs.  Are  there  serious 
flaws?  Can  they  be  compensated  by  other  measures?  Is  there 
an  increased  risk  of  containment  failure  in  a  Mark  I? 

The  second  was  an  overcharge  about  part  releases.  The 
best  documented  charge  is  over  the  1982  release  already 
discussed  by  Mr.  Abbott.  We  did  not  have  the  expertise 
or  resources  to  determine  what  was  released  and  over  how 
large  an  area. 


112 


Should  the  NRC  refuse  an  ad judicutory  hearing  on  Pilgrim 
license  then  there  should  at  least  be  NRC  or  Congressional 
hearings  on  these  two  issues. 

Finally,  I  would  like  to  touch  on  the  issue  of  Emergency 
Prepardness.  The  NRC  has  created  a  real  jurisdictional 
mess  over  this  issue.  By  requiring  local  approval  of  plans 
the  NRC  may  or  may  not  have  given  states  the  power  to  close 
plants.  How  far  this  power  actually  goes  is  unclear  but 
it  should  be  clarified  preferably  by  Congress  and  as  soon 
as  possible. 

Senator,  again  let  me  congratulate  you  for  focusing 
some  Congressional  attention  on  the  role  of  the  NCR  and 
their  performance. 


113 

The  Chairman.  Thank  you  very  much.  Senator  Golden. 

Mr.  Golden.  Mr.  Chairman,  I  want  to  thank  you  first  for  your 
continuing  and  long  standing  interest  in  this  issue,  and  particular- 
ly for  responding  to  the  request  of  local  officials  to  bring  this  hear- 
ing to  us  this  evening.  I  particularly  thank  you  for  the  opportunity 
to  testify  before  you  this  evening. 

I  believe  that  the  Pilgrim  nuclear  power  station  should  be  closed 
for  reasons  of  safety,  reliability  and  economics.  There  is  over- 
whelming evidence  that  you  will  hear  tonight  that  it  is  one  of  the 
worse  managed  nuclear  powerplants  in  the  country.  Its  contain- 
ment vessel  has  been  proven  to  be  defective,  no  emergency  plans 
exist  to  adequately  protect  the  public  in  the  event  of  a  serious  acci- 
dent at  the  plant.  Evidence  has  also  been  mounting  of  serious  secu- 
rity and  radiological  control  problems  at  the  plant,  and  a  recent 
study  has  demonstrated  that  it  would  be  less  expensive  to  shut  Pil- 
grim down  than  it  would  be  to  allow  it  to  start  up  again;  yet  no 
level  of  government  has  acted  decisively  to  shut  this  plant  down. 

Under  the  Atomic  Energy  Act,  States  have  almost  no  power  re- 
garding the  safety  of  nuclear  powerplants.  Federal  authority, 
which  is  embodied  in  the  Nuclear  Regulatory  Commission,  has  a 
virtual  monopoly  regarding  the  operation  of  nuclear  plants.  Unfor- 
tunately, the  Nuclear  Regulatory  Commission  has  failed  to  distin- 
guish between  plants  that  are  safe  and  those  that  are  not. 

Rather  than  providing  a  fair  and  open  forum  for  resolution  of 
nuclear  safety  concerns,  as  well  as  a  mechanism  for  closing  unsafe 
plants,  the  NRC  has  chosen  instead  to  be  an  advocate  of  the  nucle- 
ar industry.  Despite  all  the  well  documented  problems  at  Pilgrim, 
the  NRC  has  chosen  to  keep  the  plant  licensed. 

In  July  of  196— in  1986,  I  filed  on  behalf  of  myself  and  49  other 
State  legislators  and  Massachusetts,  Public  Interest  Research 
Group  and  other  players,  a  petition  with  the  NRC  requesting  a 
formal  hearing  on  suspension  or  revocation  of  Pilgrim's  license  to 
operate.  Both  the  Government  and  the  Attorney  General  has  since 
filed  similar  show  cause  petitions  with  the  NRC  requesting  hear- 
ings on  the  Pilgrim's  license. 

The  NRC's  failure  to  consider  fully  and  fairly  and  in  a  timely 
manner  these  petitions  has  convinced  us  that  we  cannot  rely  on 
the  NRC  to  protect  the  public  from  the  dangers  presented  by  the 
Pilgrim  nuclear  power  plant.  We  urge  and  respectfully  request  that 
you  join  our  efforts  by  using  the  power  of  this  committee  to 
demand  that  the  NRC  hold  formal  hearings,  so  that  Boston  Edison 
may  demonstrate  why  it  should  be  allowed  to  operate  a  plant  that 
is  unsafe,  unreliable  and  uneconomical. 

A  year  and  a  half  ago,  I  testified  at  length  before  the  Congres- 
sional Subcommittee  on  Energy  Conservation  and  Power  in  Wash- 
ington, DC,  on  the  problems  at  Pilgrim.  Unfortunately  very  little 
has  changed  since  that  hearing,  and  the  problems  what  I  discussed 
in  that  testimony  have  not  been  resolved.  Accordingly,  I  would  like 
to  submit  that  testimony  again  to  your  committee,  and  a  copy  of  it 
has  been  submitted.  ^ 


'  The  testimony  referred  to  appears  with  the  written  statement. 


114 

The  fact  of  the  matter  is,  Senator,  that  we  need  your  help.  We 
are  in  a  situation  where  we  have  a  utility  that  plans  to  file  for  re- 
start of  this  plan  even  though  they  don't  have  the  approved  man- 
agement performance,  even  though  there  is  no  emergency  plan  to 
adequately  protect  the  public,  even  though  the  containment  vessel 
is  flawed  and  we  have  a  90  percent  rate  of  failure  in  the  event  of  a 
serious  accident  of  the  plant,  and  even  though  radiological  control 
problems  seem  to  threaten  the  health  of  workers  and  the  general 
public.  The  NRC  has  determinedly  been  an  advocate  for  the  indus- 
try. It  has  sought  to  shut  out  public  participation. 

You  have  opened  the  door  tonight  to  that  public  participation  to 
state  and  local  officials  and  the  general  public.  We  deeply  appreci- 
ate it.  We  would  ask  that  you  continue  that  effort  by  using  the 
power  of  this  committee  to  request  the  NRC,  in  fact,  hold  an  evi- 
dentiary hearing  on  why  the  license  of  the  Boston  Edison  Co. 
should  not  be  suspended  or  revoked. 

[Applause.] 

The  Chairman.  Excellent  testimony. 

[Booing.] 

The  Chairman.  Voices  of  Boston  Edison.  Let  me  say  we  tried  to 
get  the  NRC  to  have  such  a  hearing  with  regard  to  Seabrook.  We 
were  unable  to  do  so.  We  were  joined  by  just  about  the  whole  con- 
gressional delegation — and  also  Senators  from  New  York  that — we 
work  together,  the  Senators  from  New  York  [laughter]  and  we'll 
continue  to  try  and  do  so. 

I  really  am  troubled  by  the  fact  that  we  can't  get  such  an  open 
hearing.  We  are  going  to  insist  on  it,  as  we  did  on  Seabrook.  I  men- 
tioned earlier  what  I  would  do,  if  we're  unable  to  get  the  NRC  to 
open — I  would  certainly  hope  that  they  will.  I  will  take  every 
action  I  possibly  can  to  see  that  they  do.  I  know — I'm  sure  I  speak 
for  my  colleagues.  Senator  Kerry  and  Congressman  Studds.  But  if 
we're  unable  to  do  so,  we  certainly  can  testify.  I  give  you  my  assur- 
ance I  certainly  will,  and  I'll  bring  all  the  testimony  that  we  heard 
today  and  try  to  present  it  in  as  effective  way  as  I  possibly  can. 
David  Malaguti.  Is  that  how  it's  pronounced?  Did  I  say  it  right? 

Mr.  Malaguti. 

Mr.  Malaguti.  Yes,  Senator.  As  a  matter  of  fact,  you're  just  fine. 

Senator,  I'm  the  chairman  of  the  local  Board  of  Selectmen,  and 
on  behalf  of  my  board,  I  would  welcome  you  to  Plymouth.  It  is  a 
pleasure  and  an  honor  to  have  you  here.  We  would  like  to  see  you 
more  often,  perhaps,  but  it  is  indeed  a  pleasure.  I'm  afraid  that  at 
this  point  my  testimony,  some  of  it,  might  be  old  hat,  but  I  think  it 
is  important  enough  to  state  again. 

The  Plymouth  Board  of  Selectmen  has  discussed  at  regularly 
scheduled  and  posted  meetings  and  has  taken  the  following  posi- 
tion. The  Pilgrim  power  station  should  not  be  permitted  to  restart 
until  an  effective  radiological  emergency  response  plan  approved 
by  the  town  of  Plymouth  is  in  place.  I  quote  from  the  Board's  letter 
to  the  NRC,  dated  September  2,  1987. 

The  Plymouth  Board  of  Selectmen  recommends  that  the  Pilgrim  Nuclear  Power 
Station  located  in  our  community  not  be  allowed  to  restart  until  the  radiological 
emergency  response  plan  of  this  town  is  in  an  effective  form. 


115 

That  position  statement  was  taken  after  receiving  a  first  report 
of  the  town's  Committee  on  Nuclear  Matters  dated  March  1987, 
and  on  the  advice  of  the  civil  defense  director.  Our  position  was  re- 
iterated in  a  second  letter  to  the  NRC,  dated  November  16,  1987. 

Our  present  radiological  emergency  response  plan  dated  May  1985,  is  inadequate, 
outdated  and  has  serious  deficiencies.  While  we  are  working  hard  to  bring  into 
being  a  new  plant  that  would  permit  us  to  provide  for  the  health  and  safety  of  our 
citizens  during  a  radiological  emergency,  an  approved  plan  does  not  exist  at  this 
time.  It  will  take  several  more  months  of  work  before  such  a  plan  can  be  presented 
for  the  action  of  the  Board  of  Selectmen. 

Senator,  the  magnitude  of  this  problem  can  be  glimpsed  if  you 
will  just  bear  in  mind  two  population  figures.  When  Pilgrim  station 
opened  in  1972,  the  population  of  Plymouth  was  19,000.  Today  it  is 
in  excess  of  44,000.  Our  town  is  17  miles  in  length.  Stretching  along 
the  ocean,  we  have  three  major  escape  routes:  Route  3A,  Route  44 
and  the  Route  3  Expressway.  All  routes  suffer  from  traffic  grid- 
locks periodically,  especially  during  the  tourist  season  when  people 
flock  throughout  our  historic  town.  Winter  storms,  fall  hurricanes, 
and  other  adverse  weather  conditions  only  exacerbate  the  problem. 

The  town  of  Plymouth  is  in  the  best  position  to  assess  the  pub- 
lic's safety.  We  are  the  population  most  at  risk,  and  we  have  the 
experience  of  the  years  in  dealing  with  disaster.  No  public  utility 
must  be  permitted  by  the  Nuclear  Regulatory  Agency  to  dictate  a 
evacuation  plan,  thereby  usurping  the  traditional  powers  and  au- 
thority of  the  local  elected  officials.  We  are  not  about  to  surrender 
our  rights  to  govern  ourselves.  We  are  united  with  our  Massachu- 
setts civil  defense  director,  our  State  public  safety  director  and 
with  our  governor.  We  maintain,  as  did  Governor  Dukakis  in  his 
letter  of  December  17,  1987,  that  the  Pilgrim  nuclear  power  station 
should  not  be  permitted  to  restart  the  reactor  until  all  safety  issues 
are  resolved,  and  until  adequate  approved  emergency  response 
plans  have  been  developed  by  this  town  and  state. 

We  recommend  that  your  committee  exert  congressional  pres- 
sure on  the  NRC  to  keep  the  Pilgrim  nuclear  power  station  closed 
until  an  effective  town-approved  emergency  plan  has  been  devel- 
oped for  the  safety  of  our  citizens  and  for  the  protection  of  their 
property  in  this  state. 

I  thank  you  Senator  for  the  opportunity  to  testify. 

[Additional  material  supplied  follows:] 


116 


K  ••.'.  \       ,1         M.  1'     !  !' 


\^./  iHK  shL    ;'rMi:N 


\\l'  I  1\'.1  ,     c    l.:i  .  1   .  .:  .'.  .11  .      MM 

^.M-l  1  ir.  I   ■-; .  I.I     \i.  i.:  :  i  .         ,      'i  i 


September    2,    1987 


Honorable   Lando    Zech 

Chairman 

Nuclear  Regulatory  Conmiission 

Washington,  D.C.    20555 

Dear  Chairman  Zech: 

Please  convey  to  the  Nuclear  Regulatory  Commission  the 
consensus  of  the  Plymouth  Boar^  of  Selectmen  which,  simply 
stated,  recommends  that  the  pilgrim  Nuclear  Power  Station 
located  in  our  community  not  be  allowed  to  restart  until  the 
Radiological  Emergency  Response  Plan  of  this  town  is  in  an 
effective  form.   Our  present  RERP  is  dated  May  1985  and  is 
under  intense  revision.   It  is  Inadequate  as  to  response 
time,  evacuation  procedures,  and  reception  centers. 

The  recent  FEMA  report  to  the  Nll^C  documents  the 
inadequacies  of  the  Commonweal t'->  of  Massachusetts'  RERP.   The 
Board  of  Selectmen  recognizes  ^he  same  flaws  in  the  operative 
plans  of  this  community. 

The  public  safety  would  be  at  risk  if  the  Pilgrim  Nuclear 
Power  Station  is  permitted  to  open  without  a  valid 
radiological  emergency  plan  in  place. 

We  remind  the  NRC  that  this  community  of  over  40,000 
citizens  is  entirely  within  the  ten  mile  emergency  planning 
zone  and  that  our  geographic  location  and  our  few  and  over- 
burdened evacuation  routes  pose  serious  problems  in  any 
emergency  plan,  whether  for  natural  or  radiological  disaster. 

The  issue  has  been  well  studied  and  documented  by  the  Nuclear 
Matter  Advisory  Committee  of  this  town  as  well  as  by  our 
Civil  Defense  Director. 


117 


Ilonoi  Jblo  Latuio  "f~:)<,    Cli.:irmn:i 
NucJeor  Rcqulatory  CotnnisEiun 
3eptenibir  2,  1"87 
Page  2 


The  Plymouth  Board  of  Selectmen  i ecommends  that  the  Pilgrim 
Nuclear  Power  Station  not  be  permitted  to  restart  until  an 
effective,  tested  Radiological  Emergency  Response  Plan  is  in 
place. 

i 

The'public  safety  ought  not  to  be  placed  at  risk. 
Very  truly  yours, 

David  F«  Nalagutl,  Chairman 

Board  of  Selectmen 

CO  Secretary  of  Public  Safety,  HA 

Boston  Edison,  President  <€weenev 


118 


■- 1 

•  J'  i 


M  o  \-  • 


Tho.MaL-  S.  I'uriey.  Di:.-eccor 

Office  of  iJuclcar  Reactor  Regulation 

Washington,  D.C.   2C555 

Dear  Di;.  Murlcy: 

Thank  y:>u  for  ■■our  Novercber  2,  1987,  letter  As  you  noted  in 
our  letter  of  September  2,  1987,  the  Plymouth  Board  of 
Selectmen  had  arrived,  at^.  a  ponsensus  that  the  Pilgrim  Nuclear 
Power  Station  ought  not  be  granted  permission  to  re-start 
until  an  effective  Radiological  Emergency  Response  Plan 
(RERP)  was  in  place.   An  "effective  plan"  would  be  one 
acceptable  to  FEMA  and  bearingf*its  approval. 

The  Board  reiterates  this  position  and,  in  viev;  of  the  August 
1987  report  of  the  Federal  Emergency  Management  Agency  which 
withdrew  interim  approval  of  the  existing  RERP,  the  Board 
feels  that  the  Town  of  Plymouth's  RERP  of  May  1985  is  not 
only  seriously  out-dated,  but  cannot  be  considered  an 
adequate  protection  of  the  public  safety  during  a  time  of 
potential  radiological  danger  to  our  citizens. 

Wo,  who  are  sworn  to  uphold  the  public  safety,  are  in  the 
best  position  to  know  the  present  status  of  planning  and 
readiness  in  our  community,  and  we  ask  you  to  consider  our 
views  above  all  others.   It  is  our  town,  completely  within 
the  Emergency  Planning  Zone  (EPZ) ,  and  our  citizens,  who  are 
most  at  r isk  . 

To  restate  our  position:   The  RERP  for  Plymouth  is  under 
intense  revision  and  updating  by  our  Civil  Defense 
organization  and  our  advisory  committeec.   Our  present  plan  , 
dated  May  1985  has  serious  deficiencies  and  it  will  take 
several  nonths  before  a  final  draft  can  be  brought  to  this 
Board  for  its  consideration. 

The  restart  of  the  Pilgrim  Nuclear  Power  Station  under  the 
foregoing  conditions  would  be  dangerous  and  not  in  the  public 
vjelf  are . 


119 


piGvicu.-..-     :.;'.:cn    p.o;-i:c;.d    by   trio    c: oir.Tnu r. i t y    ir    cor.iijrictio;. 
witn    t'.\c    ri\il    D^-'Lcr.de   orgar i::ations   cf    the   Ccni~.cnwealt:i    o: 
Kassac'.v.:- :tcs ,    ui.c-    ?ilcjii-i   Kuclcai    PowfJi'    Station,    v,-ith    icE 
pact    t: -.:.-. •lee",    bisiccry,    ought    not    be   ferT.ittec^   to    restart. 

Very    t v ;. _"  y    y o i; r  s  , 

BOARD   Cy    SBLiCCTMEN 

David  F.  !:alGguti 
Chairman 


cc  Peter  'vl .   Agnes,-  Jr.,  Assistant  Secretary  of  Public  Safety 
Robert  J.  Boulay,  Directors'  Mass .  Civil  Defense 
Peter  Forraan,  Representative 
Edward  P.Kirby,  Senator 

Stephen  J.  Sweeney,  President;  Boston  Edison 
Dr.  Grace  Healy,  Chairman;  Nuclear  Matters  Committee 


120 

The  Chairman.  Ms.  Shimshak. 

Ms.  Shimshak.  Thank  you,  Senator.  It's  an  honor  to  testify 
before  you  tonight,  and  also  to  sit  with  so  many  distinguished  legis- 
lative representatives,  of  which  I'm  not  one. 

My  name  is  Rachel  Shimshak.  I'm  an  advocate  for  Massachusetts 
Public  Interest  Research  Group.  MASSPIRG  is  a  statewide  organi- 
zation, working  on  consumer  and  environmental  protection  and 
energy  issues.  We  have  about  150,000  members  across  the  State.  I 
appreciate  the  opportunity  to  testify  tonight  about  the  historically 
troubled  Pilgrim  reactor. 

MASSPIRG  has  followed  the  problems  of  Pilgrim  over  the  past 
decade  and  has  conducted  several  studies  on  emergency  planning 
issues  and  the  economic  benefits  of  closing  the  reactor  and  invest- 
ing in  alternatives.  I've  brought  with  me  copies  of  those  reports 
and  I  would  like  to  submit  them  for  the  record,  if  I  could. 

In  July  of  1986,  as  Senator  Golden  mentioned,  MASSPIRG,  along 
with  many  state  legislators,  elected  officials  and  dozens  of  citizen 
groups  represented  here  tonight,  submitted  a  show  cause  petition 
to  the  Nuclear  Regulator  Commission  which  detailed  management, 
structural,  emergency  planning  and  radiological  exposure  problems 
at  the  reactor.  MASSPIRG  is  certainly  not  alone  in  its  criticism  of 
the  plan.  Reports  from  the  NRC,  the  Department  of  Public  utilities, 
the  Federal  Emergency  Management  Agency,  the  State  Depart- 
ment of  Public  Safety,  and  even  Boston  Edison's  own  review  panel, 
the  Hogan  Commission,  have  detailed  their  criticism  of  Boston 
Edison's  management  and  of  Pilgrim's  plant.  If  a  horse  had  as 
many  problems  as  the  Pilgrim  plant  has,  it  would  have  been  shot. 
[Laughter,  applause.] 

It  would  be  wise  to  acknowledge  Edison's  inability  to  correct 
these  problems  and  to  put  the  plant  out  of  its  misery  by  closing  it 
permanently. 

Today  I  would  like  to  focus  my  comments  on  the  conclusions  of 
an  emergency  planning  survey  released  this  fall  entitled  "No 
Exit".  MASSPIRG's  earlier  reports  generally  looked  at  the  adequa- 
cy of  the  emergency  plans  themselves.  This  report  approached  the 
emergency  plans  from  a  different  angle.  It  looked  not  at  the  plans 
themselves,  but  at  the  people  who  would  be  asked  to  follow  them. 
Such  information  is  crucial  to  assessing  the  feasibility  of  the  plan, 
particularly  in  light  of  the  General  Accounting  Office's  finding 
that,  quote,  "No  Federal  agency  assesses  public  knowledge  of  radio- 
logical emergency  procedures." 

In  the  summer  of  1987,  MASSPIRG  surveyed  363  residents  of  the 
Pilgrim  emergency  planning  zone  to  determine  what  people  knew 
about  the  official  emergency  plan,  and  whether  they  would  follow 
those  plans  in  case  of  an  accident  at  the  plant. 

The  key  findings  of  this  survey  show  that  residents  are  even  less 
informed  about  Pilgrim  emergency  plans  then  they  were  at  the 
time  of  MASSPIRG's  last  survey  conducted  in  1983.  Moreover,  they 
said  they  would  refuse  to  follow  official  instructions  in  the  event  of 
an  emergency.  Let  me  just  review  a  few  of  the  findings  of  the 
report. 

First,  residents  have  only  a  limited  knowledge  of  emergency 
plans  for  their  communities.  Only  56  percent  of  those  surveyed  said 
that  they  had  received  the  emergency  public  information  booklet 


121 

from  Boston  Edison,  the  operators  of  the  plant,  compared  with  67 
percent  who  remembered  receiving  the  booklet  in  1983.  Moreover, 
only  23  percent  of  those  surveyed  said  they  had  actually  read  the 
booklet,  compared  to  38  percent  in  1983. 

Second,  many  residents  would  not  follow  the  emergency  plan  in 
case  of  a  serious  problem  at  Pilgrim.  For  instance,  the  most 
common  response  to  an  accident  at  Pilgrim,  about  27  percent  of  the 
people  polled,  would  immediately  evacuate;  a  direct  contradiction 
of  the  instructions  contained  in  the  emergency  information  booklet. 
In  nice  big  letters  in  the  booklet,  incidently. 

Second,  only  19  percent  of  those  questioned  said  that  they  would 
go  to  one  of  the  designated  reception  centers  in  case  of  an  evacu- 
ation, and  two  thirds  of  those  few  who  would  follow  the  emergency 
plan,  would  go  to  the  Hanover  Mall,  which  is  no  longer  an  official 
reception  center. 

Perhaps  the  most  stunning  thing  that  we  found  concerned  school 
age  children.  Of  the  37  percent  surveyed  who  had  school  age  chil- 
dren, nearly  half  said  that  they  would  try  to  pick  up  their  school 
age  children  from  school  in  the  event  of  an  emergency.  Again,  pre- 
cisely what  the  emergency  booklet  instructed  them  not  to  do.  Just 
9  percent  of  parents  said  that  they  would  follow  the  instructions  to 
meet  their  children  outside  the  danger  zone.  And  then,  just  for 
good  measure,  79  percent  of  the  respondents  felt  that  Pilgrim 
should  remain  shut  down  if  management  and  safety  problems  per- 
sist. 

Allowing  the  Pilgrim  plant  to  reopen  in  light  of  these  results  and 
the  serious  management  and  safety  problems  that  persist  at  the 
plant,  would  be  like  giving  a  drunk  the  keys  to  drive  home.  MAS- 
SPIRG  recommends  that  the  Pilgrim  plant  not  be 

The  Chairman.  Did  they  indicate  who  those  9  percent  parents 
were  that  were  going  to  leave  their  children?  [Laughter.] 

Ms.  Shimshak.  Nine  percent  said  that  they  would  actually 
follow,  I 

The  Chairman.  I  guess  that  doesn't  say  they  would  actually 
leave  them. 

Ms.  Shimshak.  Right. 

The  Chairman.  It  doesn't  include,  as  I  understand  it,  the  chil- 
dren going  to  private  schools;  is  that  correct? 

Ms.  Shimshak.  There  are  currently  no  plans  for  those  people. 

The  Chairman.  What  do  they  do?  Do  they  stay  behind  and  take 
that  wonderful  tablet? 

Ms.  Shimshak.  Perhaps  they  could  wait  for  the  buses,  for  the 
buses  to  arrive  from  Boston  to  pick  them  up. 

The  Chairman.  A  serious  question.  Do  you  know  the  number  of 
children  that  would  be  in  the  private  and  parochial  schools;  are 
there  many? 

Ms.  Shimshak.  I'm  sure  that  there  are,  but  perhaps  you  can. 

Mr.  Malaguti.  I  don't  have  the  numbers. 

The  Chairman.  OK,  please  continue. 

Ms.  Shimshak.  MASSPIRG  recommends  that  the  Pilgrim  plant 
not  be  opened  unless  it  is  determined  that,  one:  a  workable  plan 
can  be  developed;  two:  such  plans  have  been  effectively  disseminat- 
ed and  implemented,  and  three:  that  outstanding  management, 
safety  and  economic  questions  have  been  resolved. 


122 

We  also  recommended  that  Boston  Edison  use  this  unique  oppor- 
tunity to  implement  the  conservation  and  load  management  recom- 
mendations of  the  Hogan  report,  rather  than  spend  more  money  on 
this  plant.  Thank  you. 

[The  prepared  statement  of  Ms.  Shimshak  follows:] 


123 


A4ifS5PIRG 

MASSACHUSETTS  PUBUC  INTEREST  RESEARCH  GROUP 

Testimony  of 

Rachel  Shlmshak 
Advocate,  Massachusetts  Public  Interest  Research  Q*oup 

Before  the 
Labor  and  Human  Resources  Committee  of  the  United  States  Senate 


Concerning  public  health  impacts  associated  with  proposed  restart  of 
Pilgrim  I  nuclear  power  plant 


January  7,  1988 


29  Temple  Place,  Boston,  MA  02111  (617)  292-4800 


124 


Good  ev«nin(j,  Mr.  Cnairnan  and  members  of  the  Committee.  My  naae  is 
Rachel  Shimahak  and  I  an  an  advocate  for  the  Massachusetts  Public  Interest 
Research  O-oup  (MASSPIRC).  MASSPIRG  is  a  statewide  organization  worlclng  on 
consuoar  and  environioental  protection  and  energy  Issues.  We  have  over  170,000 
citizen  oembers  across  the  state  of  Massachusetts. 

I  appreciate  the  opportunity  to  appear  before  you  today  to  discuss  the 
historically  troubled  Pilgrim  reactor.   MASSPIRG  has  followed  the  problems  at 
Pilgrim  over  the  past  decade  and  has  conducted  several  studies  on  emergency 
planning  issues  and  the  economic  benefits  of  closing  the  reactor  and 
investing  in  alternatives.   In  July  of  1986,  MASSPIRG,  along  with  50  state 
legislators  and  over  a  dozen  citizen  groups,  submitted  a  "Show  Cause"  petition 
to  the  Nuclear  Regulatory  Commission  (NRC)  which  detailed  management, 
structural,  emergency  planning  and  radiological  exposure  problems  at  the 
reactor . 

MASSPIRG  is  certainly  not  alone  in  its  criticism  of  the  plant.   Reports 
from  the  NRC,  the  Department  of  Public  Utilities,  the  Federal  Emergency 
Management  Agency,  the  state's  Department  of  Public  Safety,  and  even  Boston 
Edison's  own  review  panel  (the  Hogan  Commission)  have  detailed  their  criticism 
of  Boston  Edison  and  the  Pilgrim  plant.   If  a  horse  had  as  many  problems  as 
the  Pilgrim  plant  has,  it  would  have  been  shot.   In  our  Judgment,  it  would  be 
wise  to  acloiowledge  Edison's  inability  to  correct  these  problems  and  put  the 
plant  out  of  its  misery  by  closing  it  permanently. 

Today  I  would  like  to  focus  my  comments  on  the  conclusions  of  an 
emergency  planning  survey  we  released  this  fall  entitled,  "No  Exit." 
MASSPIRG' 3  earlier  reports  generally  looked  at  the  adequacy  of  the  emergency 
plans  themselves.   This  report  approached  the  emergency  plans  from  a  different 
angle — it  looked  not  at  the  plans  themselves  but  at  the  people  who  will  be 
asked  to  follow  them.   Such  information  is  crucial  to  assessing  the 


125 


feasibility  of  the  plana,  particularly  in  light  of  the  General  Accounting 
Office's  finding  that  "no  federal  agency  assesses  public  knowledge  of 
radiological  emergency  procedures."   ( GAO  Report  to  Hon.  Edward  J.  Markey, 
House  of  Representatives,  "Nuclear  Regulation:   Public  Knowledge  of 
Radiological  Emergency  Procedures,"  June  1987,  p.  1) 

In  the  summer  of  1987,  MASSPIRG  surveyed  363  residents  of  the  Pilgrim 
emergency  planning  zone  (EPZ)  to  determine  what  people  knew  about  the 
official  emergency  plans  and  whether  they  would  follow  those  plans  in  case  of 
an  accident  at  the  plant. 

The  key  findings  of  this  survey  show  that  residents  are  even  less 
informed  about  Pilgrim  emergency  plans  than  they  were  at  the  time  of 
MASSPIRG's  last  such  survey,  conducted  in  1983-   Moreover,  they  refused  to 
follow  official  instructions  in  the  event  of  an  emergency. 

Let  me  review  a  few  of  the  findings  in  the  report: 

1 )  Residents  have  only  a  limited  knowledge  of  emergency  plans  for 
their  communities.   Only  55}  of  those  surveyed  said  they  had 

received  the  Emergency  Public  Information  booklet  from  Boston  Edison,  the 
operator  of  the  plant,  compared  with  57»  who  remembered  receiving  the  booklet 
in  1983.   Moreover,  only  235  of  those  surveyed  said  they  had  actually  read  the 
booklet  completely,  compared  to  38'  in  1983. 

2)  Many  residents  would  not  follow  the  emergency  plans  in  case 
of  a  serious  problem  at  Pilgim: 

•  the  most  common  response  to  an  accident  at  Pilgrim  (27? 

of  those  polled)  would  be  immediate  evacuation--a  direct  contradiction  of 
instructions  contained  in  the  emergency  information  booklet; 

•  only  19'  of  those  questioned  said  they  would  go  to  one 

of  the  designated  reception  centers  in  case  of  an  evacuation,  and  two-thirds 


126 


of  these  few  who  would  follow  the  emergency  plans  would  go  to  the  Hanover 
Mall,  which  is  no  longer  an  official  reception  center; 

•  of  the  37S  surveyed  who  have  school-age  children, 

nearly  half  iUSi)   said  that  they  would  try  to  pick  up  their  children  from 
school  in  the  event  of  an  emergency — precisely  what  the  emergency  booklet 
instructs  them  not  to  do;  just  95  of  parents  said  they  would  follow  the 
Instructions  to  meet  their  children  outside  the  danger  zone. 

*  Seventy-nine  percent  of  the  respondents  felt  that  Pilgrim  should 
remain  shut  down  if  management  and  safety  problems  persist. 

Allowing  the  Pilgrim  plant  to  reopen  in  light  of  these  results  and  the 
serious  management  and  safety  problems  that  persist  at  the  plant  would  be  like 
giving  a  drunk  the  keys  to  drive  home.  MASSPIRG  recommends  that  the  Pilgrim 
plant  not  reopen  unless  it  is  determined  that: 

1)  workable  plans  can  be  developed; 

2)  such  plans  have  been  effectively  disseminated  and  implemented;  and 

3)  outstanding  managment,  safety,  and  economic  questions  have  been 
resolved . 

We  also  recommend  that  Boston  Ediston  use  this  unique  opportunity  to 
implement  the  conservation  and  load  managment  recommendations  of  the  Hogan 
report  rather  than  spend  more  money  on  this  plant. 

Thank  you  very  much. 


127 

The  Chairman.  I  want  to  move  along,  but  I  have  some  questions. 
First  of  the  legislators.  First  of  all,  I  congratulate  you  on  the  report 
that  was  made  for  the  Joint  Special  Committee,  and  I'm  going  to 
make  the  recommendation  contained  in  the  report  a  part  of  the 
hearing  record  as  well. 

Representative  Forman  spoke  about  the  adequacy  of  the  ability 
of  local  and  State  governments  to  deal  with  some  of  the  NRC  rul- 
ings. 

Do  you  have  suggestions  of  ways  in  which  the  NRC  should 
expand  the  role  of  the  State  and  local  communities?  Or  if  you  want 
to  think  about  it,  you  can  later  make  it  a  part  of  the  record. 

[Excerpts  from  the  report  referred  to  above  follows:] 


128  ' 


SENATE No.    2023 


Z'ht  CommontDtaltt  of  0iaMat!bnietti 


REPORT 

of  the 

JOINT  SPECIAL  COMMITTEE 

ESTABLISHED  FOR  THE  PURPOSE 

OF  MAKING  AN  INVESTIGATION  AND  STUDY 

Relative  to 

THE  PILGRIM  NUCLEAR  GENERATING 
FACILITY  AT  PLYMOUTH 


(under  the  provisions 
of  Senate  Order  No.  2044 
adopted  in  the  year  1986). 


July,  1987 


129 
SENATE  -  No.  2023 

Z>f)t  CommontDealtt  ot  0iasiiad)ufitttii 


FOREWORD 


The  Pilgrim  Nuclear  Generating  Station  has  been  shut  down  since 
April  1986.  The  Nuclear  Regulatory  Commission  has  been  sharply 
critical  of  the  Boston  Edison  Company's  management  of  the  plant. 

The  Massachusetts  Legislature  responded  with  the  establishment 
of  a  special  joint  committee  to  investigate  and  study  the  problems  at 
the  facility.  This  report  is  the  culmination  of  the  committee's  work. 

We  recognize  that  this  is  not  the  final  work  on  Pilgrim.  Debate  over 
Boston  Edison's  improvements,  possible  re-start,  and  how  fully  our 
recommendations  are  followed  will  continue.  We  also  recognize  that 
state  authority  over  nuclear  power  is  limited.  Thus  our  recommen- 
dations should  be  seen  in  that  light. 

We  do  hope,  however,  that  the  report  will  serve  as  a  major  reference 
point  as  public  debate  continues  and  decisions  are  made.  As  Chairmen 
of  the  committee,  our  aim  was  to  provide  an  open  forum  where  all 
the  issues  could  be  reviewed  objectively. 

We  have  succeeded  in  our  efforts  if  the  report  contributes  to  the 
enhancement  of  public  safety  and  public  health  in  the 
Commonwealth. 

Finally,  we  wish  to  thank  the  committee  members  for  their  hard 
work  and  patience,  as  well  as  the  individuals  and  agencies  identified 
herein  that  contributed  greatly  to  this  report. 


SENATOR  THOMAS  C.  NORTON, 
Senate  Chairman. 


REPRESENTATIVE  PETER  FORMAN, 
House  Chairman. 


130 
SENATE  -  No.  2023  [August 


This  report  has  been  prepared  by  Brian  J.  Prenda, 
M.P.A.,  Lisa  Kaminski,  Kevin  Considine,  Linda  Marley 
and  Liicy  DeLaney  for  the  Special  Committee  to 
investigate  and  study  the  Pilgrim  Station  Nuclear  facility 
at  Plymouth. 

The  staff  of  the  Special  Committee  extends  its  sincere  thanks  to 
those  who  so  generously  contributed  their  time  and  expertise  to  the 
preparation  of  this  report. 


131 

1987]  SENATE  -  No.  2023  97 

RECOMMENDATIONS 

I)    Creation  of  the  Division  of  Nuclear  Facilities  Safety. 

II)    Endorsement   of  Comprehensive    Load    Management   and 
Conservation  Programs. 

Ill)   Prioritize    Massachusetts    Based    Electrical   Generating 
Facilities. 

IV)  Department  of  Public  Utilities  to  Establish  a  Five-year 
Supply  Plan  without  reliance  on  the  Pilgrim  Plant. 

V)  Committee  Review  of  the  Nuclear  Regulatory  Commission 
(NRC)  Systematic  Assessment  of  Licensee  Performance 
Report  (SALP)  and  Recommended  Measures  to  Correct 
Serious  Functional  Deficiencies  at  the  Pilgrim 
Nuclear  Generating  Facility  at  Plymouth. 

VI)  Improved  Emergency  Preparedness  Plan. 


132 

98  SENATE  —  No.  2023  [August 

RECOMMENDATION  I 

CREATION  OF  A  DIVISION  OF 
NUCLEAR  FACILITY  SAFETY 

After  many  hours  of  deliberation  over  topics  such  as  emergency 
preparedness  and  planning,  monitoring  of  radiation  and  other  aspects 
of  nuclear  safety,  the  committee  has  concluded  that  many  areas 
regarding  public  safety  need  immediate  attention  and  improvement. 
After  reviewing  and  hearing  the  testimony  of  the  Department  of 
Public  Health  (DPH)  and  the  Department  of  Public  Safety,  the 
committee  concluded  that  lack  of  funding,  along  with  shortfalls  in 
strict  compliance  with  many  sections  of  Chapter  796  of  the  acts  of 
1979,  have  led  to  a  less  than  appropriate  handling  of  radiation 
monitoring  and  emergency  preparedness.  The  committee,  therefore, 
recommends  that  the  Commonwealth  adopt  and  implement  the 
formation  of  a  Division  of  Nuclear  Facility  Safety  to  oversee  nuclear 
generated  power  production  in  the  Commonwealth. 

The  Division  of  Nuclear  Facility  Safety  shall  provide  the  following 
provisions  and  services: 

The  Division  of  Nuclear  Facility  Safety  shall  be  a  division  of  the 
Department  of  Public  Safety  and  shall  be  responsible  for  monitoring 
the  operation  and  modification  of  the  two  nuclear  power  plants  within 
the  Commonwealth.  In  addition,  it  shall  be  responsible  for  developing 
emergency  response  plans  in  conjunction  with  Massachusetts  Civil 
Defense  for  responding  to  accidents  involving  nuclear  power  plant 
facilities.  Major  activities  shall  include:  installation,  operation  and 
maintenance  of  a  system  for  remote  monitoring  of  radioactive 
discharges  from  the  nuclear  power  plants,  in  conjunction  and  under 
the  supervision  of  the  Department  of  Public  Health;  development  and 
review  of  the  Massachusetts  Radiological  Accident  Emergency 
Preparedness  Plan  (MRAEPP);  oversight  of  training  of  state  and 
local  civil  defense  personnel  responsible  for  implementation  of  the 
MRAEPP.  Enforcement  of  rules  and  regulations  prescribing 
standards  for  in  service  testing  of  pressurized  systems  at  nuclear  power 
plants  which  the  Department  of  Public  Safety  oversees. 

1)  The  Massachusetts  Radiological  Accident  Emergency  Prepared- 
ness Plan. 

The  Massachusetts  Radiological  Accident  Emergency  Prepared- 


133 


1987]  SENATE  -  No.  2023  99 

ness  Plan  shall  establish  a  program  for  statewide,  integral 
management  procedures  in  the  event  of  an  accident  which  may  occur 
at  a  nuclear  power  reactor  site.  The  primary  purpose  of  the  plan  is 
to  provide  a  coordinated  response  by  state  and  local  governmental 
officials  for  the  protection  of  the  citizens  of  the  Commonwealth.  The 
plan  shall  include  site  specific  planning  to  cover  the  urgency  of 
protecting  citizens  living  near  nuclear  plants;  a  concept  of  operations 
so  that  the  plan  can  be  effectively  carried  out;  and  an  effective 
allocation  of  resources  and  personnel.  The  plan  shall  pre-assign  the 
duties  and  responsibilities  that  would  be  taken  by  all  the  respondents 
to  a  nuclear  accident  thus  enabling  actions  to  be  made  quickly  and 
efficiently. 

The  Massachusetts  Division  of  Nuclear  Facility  Safety  and  the 
Massachusetts  Civil  Defense  Agency  shall  share  the  primary 
responsibility  for  developing  the  plan  with  integral  component 
agencies  such  as  the  state  police  and  the  Emergency  Planning  Zone 
(EPZ)  communities'  local  officials.  The  utilities'  security  and  safety 
personnel  must  also  play  a  major  role  in  planning.  Specifically,  the 
Division  of  Nuclear  Facility  Safety  shall  be  responsible  for  the 
technical  functions  of  this  effort,  and  the  Civil  Defense  Agency  shall 
be  responsible  for  the  operational  aspects.  The  plan  shall  be  reviewed 
every  year  for  accuracy  and  proper  appropriation  to  assure  a  fully 
functional  quality  plan.  The  appropriate  components  shall  be 
distributed  to  the  proper  state,  county  and  municipal  agencies  and 
organizations  in  the  Commonwealth  for  implementation. 

The  Division  of  Nuclear  Facility  Safety  shall  plan  to  expand  the 
EPZ  to  50  miles  from  each  reactor  with  the  understanding  that  greater 
planning  and  preparedness  efforts  are  necessary  closer  to  the  reactor 
and  that  evacuation  will  not  likely  be  recommended  for  all  areas 
within  a  50-mile  radius.  These  plans  should  be  tailored  to  meet  each 
community's  specific  needs. 

The  Division  of  Nuclear  Facility  Safety  shall  clarify  evacuation 
plans  for  regional  schools  which  have  students  from  at  least  one,  but 
not  all,  towns  in  the  school  system  which  are  part  of  an  EPZ.  Division 
and  Civil  Defense  officials  working  with  school  administrators  and 
parents'  groups  must  develop  workable  student  and  teacher 
evacuation  plans  and  establish  criteria  for  determining  when,  if  ever, 
it  would  be  appropriate  to  send  children  home  first  to  evacuate  with 
their  families. 

The  Division  of  Nuclear  Facility  Safety  shall  establish  emergency 


134 


100  SENATE  —  No.  2023  [August 

evacuation  time  estimates  and  traffic  control  plans  based  on 
evacuations  of  people  within  the  EPZ  to  reception  centers  at  least  30 
miles  from  the  reactor  and  should  anticipate  secondary  or  shadow 
evacuations. 

The  Division  of  Nuclear  Facility  Safety  shall  commission  a  site- 
specific  probabilistic  risk  analysis  of  severe  accident  probabilities  at 
Pilgrim  and  the  consequences  of  radioactive  releases  and  the  probable 
health  effects  at  various  distances  from  the  plant. 

Major  operations  specified  in  the  Plan  and  agency  responsibilities 
are  outlined  in  Recommendation  VI. 

2)  Monitoring. 

The  committee  recommends  that  the  Division  of  Nuclear  Facility 
Safety  and  the  Department  of  Public  Health  adopt  and  develop  a 
Remote  Monitoring  System  (RMS)  which  shall  incorporate  three 
major  components:  gross  gamma  detectors  radially  positioned  around 
each  nuclear  power  station;  an  automated,  isotopic  gaseous  effluent 
monitor  system  which  samples  from  major  engineering  release  points; 
and  a  reactor  parameter  data  communication  link  to  each  facilities' 
on-site  computer.  In  addition  there  shall  be  provided  liquid  effluent 
monitors,  which  will  be  located  at  each  plant's  liquid  discharge  points. 
All  of  these  RMS  components  shall  be  connected  through  a  dedicated 
data  communications  link  to  provide  instantaneous  readings  to  the 
Division  of  Nuclear  Facility  Safety  Headquarters.  Technical  staff 
shall  review  the  data  and  perform  analyses  of  plant  conditions. 

a)  ENVIRONMENTAL  RADIATION  MONITORING  SYS- 
TEM: The  Division  of  Nuclear  Facility  Safety  shall  develop  a  dual 
ring  system  of  environmental  radiation  monitors  utilizing  gross 
gamma  detectors  and  automated  isotopic  detectors  which  shall  be 
installed  and  maintained  around  each  reactor  site  that  would  measure 
a  change  in  radiation  levels  resulting  from  a  radioactive  release  at  the 
reactor  site.  This  system  shall  serve  a  multitude  of  purposes.  It  shall 
define  the  existence  of  a  radioactive  release  sufficiently  large  enough 
to  impact  upon  the  environment,  as  well  as  detect  a  release  through 
an  unmonitored  release  path.  In  addition,  the  system  shall  provide 
a  backup  capability  should  the  effluent  monitoring  system  be 
inoperable,  and  shall  also  help  reveal  the  presence  of  atmospheric 
conditions  (windshear)  which  could  result  in  plume  dispersal  not 
following  anticipated  direction  of  travel. 

The   Environmental    Radiation    Monitoring   System   shall   be 


135 


1987]  SENATE  -  No.  2023  101 

developed  to  provide  the  following  features:  (1)  up  to  16  monitors 
per  site  (1  detector  for  each  22.5  degree  segment)  at  a  distance  of 
approximately  2  miles  from  the  reactor  site;  (2)  minimum  detection 
level  of  1  microRoentgen  per  hour  (natural  background  levels  are 
approximately  7  to  10  micro  Roentgens  per  hour);  (3)  maximum 
detection  limit  is  at  least  10  Roentgens  per  hour  (one  million  times 
normal  background  levels);  (4)  automatic  transmission  of  radiation 
readings  to  the  Nuclear  Facility  Safety  Division  headquarters 
computer  system  every  8  minutes;  and  (5)  transmission  of  alarm 
signals  to  the  Nuclear  Facility  Safety  Division  headquarters  in  the 
event  of  high  radiation  levels  or  failure  of  environmental  monitoring 
system  components. 

b)  REACTOR  PARAMETER  DATA  LINK:  The  Massachusetts 
Division  of  Nuclear  Facility  Safety  shall  install  a  direct  data 
communication  link  between  the  Division  headquarters  computer  and 
each  nuclear  reactor's  control  room  computer  for  the  monitoring  of 
the  Commonwealth's  two  nuclear  power  reactors  and  their  safety 
systems.  This  data  link  shall  be  developed  for  early  notification  of 
events  that  could  lead  to  nuclear  accidents.  This  system  is  an  essential 
element  in  providing  continuous  plant  safety  assessment,  early 
detection  of  abnormal  conditions,  and  evaluation  of  nuclear  plant 
transients. 

The  system  signals  to  be  received  at  the  Division's  headquarters 
shall  be  the  same  signals  available  to  the  nuclear  plant  personnel  on- 
site.  The  Division  shall  select  particular  parameters  to  be  transmitted 
to  them  from  an  index  containing  all  available  plant  system 
information.  Parameters  selected  by  the  Department  provide  detailed 
information  on  the  operation  characteristics  of  all  essential  plant 
safety  systems. 

Some  major  features  that  are  available  that  may  be  included  in  this 
system  are:  (1)  1,000  to  1,300  parameters  (signals)  per  reactor 
accessible  for  transmission  every  two  minutes;  (2)  technical 
parameters  include:  reactor  power  levels,  reactor  water  levels,  steam 
generator  water  levels,  containment  temperatures,  engineered  safety 
system  availability,  and  essential  pump  flow  rates;  and  (3)  system 
software  for  displaying  either  current  or  historical  signals. 

c)  THE  RADIOACTIVE  GASEOUS  EFFLUENT  MONITOR- 
ING SYSTEM:  The  Division  of  Nuclear  Facility  Safety  and  the 
Department   of   Public    Health   shall   be   directed   to   utilize   and 


136 


102  SENATE  -  No.  2023  [August 

implement  a  custom  designed  automated  system  to  monitor  gases 
routinely  released  by  nuclear  power  plants.  The  Radioactive  Gaseous 
Monitoring  System  is  designed  to  identify  and  quantify  the 
radioactive  components  of  the  gaseous  discharges  from  each  stack  and 
other  gaseous  release  points  to  the  environment  and  transmit  the 
information  immediately  to  the  Division  so  that  appropriate 
emergency  action  can  be  directed  in  the  event  of  a  nuclear  accident. 

The  Radioactive  Gaseous  Effluent  Monitoring  System  is  a  state  of 
the  art,  computerized  system  which  continuously  transmits  data  from 
the  nuclear  power  plant  to  the  Division's  headquarter  computer. 

This  system  includes  the  following  features:  (1)  dedicated  computer 
at  the  power  plant  sites  for  operation  and  analysis;  (2)  minimum 
detection  level  of  10  to  13  microCuries/ cubic  centimeter;  (3) 
maximum  accident  detection  limit  of  10  microCuries/cubic 
centimeter;  (4)  collection  and  analyses  of  radiation  in  three  forms: 
iodines,  particulates,  and  noble  gases;  (5)  automatic  background  level 
checks;  (6)  automatic  check  on  source  verifications;  (7)  remote 
computer  access  to  determine  operational  status  and  data;  (8)  signal 
alarms  in  the  event  of  high  radiation  levels  or  failure  of  a  system 
function;  (9)  detection  of  specific  isotopes  based  on  radiation  energy; 
and  (10)  accelerated  operation  rates  designed  to  maximize  data 
collection  during  an  accident. 

d)  EMISSION  STANDARDS:  It  is  essential  that  Massachusetts 
Public  Health  Officials  review  and  determine  the  maximum 
permissible  levels  of  airborne  radioactive  emissions  from  nuclear 
power  plants  that  do  not  threaten  the  public  health  and  safety.  By 
adopting  state  emission  standards  as  authorized  by  the  Clean  Air  Act 
amendments  of  1977,  the  Commonwealth  will  ensure  that  safe 
standards  are  in  place  and  strictly  enforced.  Until  such  standards  are 
set  by  the  Department  of  Public  Health,  the  federal  standards  should 
be  adopted  as  state  standards  so  that  the  state  officials  immediately 
have  the  power  to  inspect  onsite  and  off-site  monitoring  equipment 
and  have  independent  enforcement  authority  over  emissions.  The 
state  shall  assess  all  licensees  for  the  cost  of  setting  up  a  monitoring 
system  for  the  Commonwealth. 

Perhaps  the  most  important  safety  function  of  a  monitoring  system 
is  to  assist  emergency  response  officials  in  determining  the  extent  of 
a  serious  accident  and  the  amount  and  direction  of  radiation  releases. 
We  recommend  installation  of  a  comprehensive  and  sophisticated  new 


137 


1987]  SENATE  -  No.  2023  103 

monitoring  system  similar  to  the  one  that  is  already  installed  and 
functioning  in  Illinois  to  provide  substantially  more  public  protection. 

3)  Possible  Adverse  Health  Effects  From  Pilgrim  Radioactive 
Emissions 

a)  Radiation  exposure  can  cause  cancer,  birth  defects  and 
chromosomal  damage.  The  Department  of  Public  Health  has 
determined  that  there  has  been  a  significant  increase  in  leukemia  cases 
in  the  area  surrounding  Pilgrim,  although  the  department  is  still 
studying  what  the  cause  of  those  leukemias  may  be. 

b)  The  Special  Committee  recommends  that  four  health  studies  be 
conducted: 

1)  A  follow-up  study  on  the  leukemia  cases  in  the  Plymouth  area 
to  determine  what  environmental  or  occupational  exposures  may 
have  caused  those  leukemias. 

2)  A  study  to  test  the  theory  that  coastal  winds  may  concentrate 
the  radioactive  emissions  from  the  Pilgrim  plant  in  such  a  way 
as  to  cause  adverse  health  consequences  in  coastal  areas. 

3)  A  regional  study  of  adverse  health  impacts,  including  leukemia 
incidences,  birth  defects  and  infant  mortality,  downwind  from 
other  nuclear  reactors  in  New  England. 

4)  A  health  study  of  all  past  and  present  Pilgrim  employees  to 
determine  the  adverse  effects,  if  any,  of  exposure  to  radiation 
from  Pilgrim. 

4)  The  cost  of  the  Division  of  Nuclear  Facility  Safety  and  the 
Department  of  Public  Health's  monitoring  system  should  not 
be  borne  by  all  taxpayers  but  by  the  utility  ratepayers  through 
an  assessment  of  the  nuclear  plant  licensees. 


138 

104  SENATE  -  No.  2023  [August 

RECOMMENDATION  II 


ENDORSEMENT  OF  COMPREHENSIVE  LOAD 
MANAGEMENT  AND  CONSERVATION  PROGRAMS 

The  special  committee  investigating  the  Pilgrim  Nuclear  Generating 
Facility  reviewed  testimony  involving  energy  supply,  load 
management  and  conservation  measures  during  several  hearings.  The 
committee  concluded  that  in  order  to  meet  current  and  future  power 
supply  demands  all  utilities  in  the  Commonwealth  must  implement 
stringent  load  management  and  conservation  programming.  The 
committee  stresses  that  authority  should  be  given  to  the  Department 
of  Public  Utilities  to  oversee  the  implementation  of  aggressive  load 
management  and  conservation  programs  for  any  electric  utility  relying 
on  the  continual  operation  of  the  Pilgrim  Generating  Facility. 

Load  Management 

The  committee  endorses  the  concepts  contained  in  the  Final  Report 
of  the  Boston  Edison  Review  Panel  as  they  relate  to  increased  load 
management  programs  by  Boston  Edison  Company.  The  committee 
recommends  that  the  Department  of  Public  Utihties  (DPU)  be 
required  to  encourage  and  assist  Boston  Edison  in  implementing  the 
specific  load  management  programs.  The  DPU  shall  also  be  required 
to  encourage  and  assist  Commonwealth  Electric  Company  in 
implementing  appropriate  cost-effective  load  management  programs 
that  offer  the  company  similar  energy-saving  results. 

Boston  Edison  Company  should  identify  and  fund  effective  "load 
management"  measures,  such  as  radio-controlled  water  heaters  and 
nighttime  water  chilling  systems,  which  reduce  peak  energy  use  and 
are  cheaper  than  the  cost  of  producing  electricity  from  new  power 
plants.  In  addition,  the  utility  should  provide  incentives  for 
commercial  and  industrial  sector  customers  to  form  "load-shedding 
cooperatives,"  where  a  group  of  participants  agrees  to  share  minimal 
energy  use  reductions  during  peak  demand  emergencies. 


139 

1987]  SENATE  -  No.  2023  105 

Conservation 

The  special  committee  endorses  the  concepts  contained  in  the  Final 
Report  of  the  Boston  Edison  Review  Panel  as  they  relate  to  increased, 
cost-effective  conservation  programs  by  Boston  Edison  Company. 
The  DPU  should  be  required  to  encourage  and  assist  Boston  Edison 
in  implementing  the  specific  conservation  programs.  The  DPU  shall 
also  be  required  to  encourage  and  assist  Commonwealth  Electric 
Company  in  implementing  appropriate,  cost-effective  conservation 
programs  that  offer  the  company  similar  energy-saving  results.  The 
DPU  should  direct  all  utilities  to  make  significant  investments  in 
energy  conservation  and  energy  efficiency  programs,  known  as 
"demand-side  management"  programs,  to  reduce  the  energy  demand 
of  all  utilities' customers.  The  DPU  should  set  target  investment  levels 
and  participate  in  the  design  of  demand-side  management  programs. 
Such  programs  should  include,  but  not  be  limited  to  the  following, 
where  shown  to  be  cost  effective: 

1)  The  special  committee  recommends  all  utilities  should  employ 
d.esign  teams  to  go  into  buildings  that  use  large  quantities  of 
electricity  to  identify  the  full  package  of  demand-side 
management  measures  and  practices  that  are  cheaper  than  the 
utilities  commensurate  cost  of  producing  electricity  from  new 
power  plants  over  the  useful  life  of  the  conservation  measures. 
The  utility  should  then  fund  the  purchase  and  installation  of 
identified  cost-effective  measures. 

2)  All  electric  utility  companies  should  offer  their  customers 
incentives  for  a  wide  range  of  efficiency  measures.  This  incentive 
program  should  go  far  beyond  the  limited  scope  of  current  and 
prior  utility  rebate  programs  for  refrigerators  and  efficient  lights. 

3)  All  electric  utility  companies  should  also  provide  incentives  for 
electrical  energy  efficiency  in  new  construction  including  hook- 
up fee  and  penalties. 

4)  All  electric  utility  companies  should  convene  an  auction  for 
energy  efficiency  improvements  similar  to  the  bidding  process 
that  is  currently  being  used  to  promote  the  development  of  small 
power  and  co-generation  facilities. 


140 


106  SENATE  -  No.  2023  [August 

5)  The  committee  recommends  that  the  DPU  should  be  allowed 
to  provide  all  utilities  with  a  profit,  or  "rate  of  return"  on  the 
investment  the  company  makes  in  demand-side  management 
programs.  This  rate  of  return,  to  be  recovered  from  the 
company's  ratepayers,  could  be  at  least  as  high  and/ or  up  to  two 
percentage  points  higher  than  the  rate  the  utilities  are  authorized 
to  receive  for  capital  investments  in  new  power  plants. 


141 

1987]  SENATE  -  No.  2023  107 

RECOMMENDATION  III 


PRIORITIZE  MASSACHUSETTS  BASED  ELECTRICAL 
GENERATING  FACILITIES 

I.  The  Committee  recommends  that  the  Energy  Facilities  Siting 
Council  and  the  Department  of  Public  Utilities  give  priority 
consideration  to  the  construction  of  non-nuclear  electric  generating 
plants  located  within  the  Commonwealth  when  reviewing  the  plans 
of  any  electric  utility  for  the  construction  of  a  new  generating  plant. 

The  Massachusetts  General  Laws  and  regulations  promulgated  by 
regulatory  agencies  require  utility  companies  to  provide  ratepayers 
with  electricity  at  the  lowest  possible  economic  cost  and  with  the  least 
possible  environmental  impact.  In  planning  to  meet  the  electrical 
energy  needs  of  ratepayers,  the  Department  of  Public  Utilities,  the 
Energy  Facilities  Siting  Council,  and  the  utilities  should  consider  and 
evaluate  the  following  factors: 

1)  The  full  "life  cycle"  economic  costs  of  each  energy  resource 
option.  These  include  costs  for  construction,  financing, 
operation  and  maintenance,  and  decommissioning.  With  respect 
to  energy  efficiency  and  load  management  programs,  costs  for 
materials  and  installation  and  program  administration  should 
be  considered. 

2)  The  full  environmental  costs  of  each  energy  resource  option. 
Environmental  impacts  associated  with  the  siting  of  facilities, 
degradation  of  outdoor  and  indoor  air  quality,  potentially 
adverse  impacts  on  water  quality,  and  risks  to  public  health 
should  all  be  fully  considered  when  deciding  which  energy  option 
to  pursue. 

3)  The  number  of  jobs  created  by  the  use  of  each  energy  resource 
option.  The  number  of  long-  and  short-term  jobs  that  are  directly 
and  indirectly  created  as  a  result  of  developing  various  energy 
resource  options  should  be  considered  and  compared.  Other 
state  and  local  economic  development  costs  and  benefits,  such 
as  support  of  indigenous  industry  and  inflows  or  outflows  of 


142 


108  SENATE  -  No.  2023  [August 

capital  resulting  from  development  of  each  energy  resource 
option  should  also  be  considered. 

4)  The  reliability  of  the  energy  resource  option.  Massachusetts 
needs  affordable  and  reliable  energy  resources  to  help  sustain 
a  healthy  economy.  Energy  resource  options  that  decentralize 
and  diversify  the  region's  fuel  mix,  and  which  reduce  reliance 
on  non-indigeous  fuels,  should  be  prioritized. 

All  potential  resource  options  —  including  energy  efficiency 
improvements  and  practices,  load  management  measures  and 
practices,  small  power  production,  co-generation,  and  small  and  large 
oil,  natural  gas  and  clean  coal  technologies  should  be  evaluated  and 
compared  using  the  above  criteria. 

The  Committee  believes  that  priority  should  be  given  to 
Massachusetts  based  plants.  The  Committee  is  concerned  about  the 
increased  dependence  on  plants  located  outside  Massachusetts  for  our 
electric  generating  needs.  It  believes  that  this  trend  increases  the 
likelihood  of  supply  disruptions,  thereby  complicating  unduly  our 
ability  to  forecast  long  range  supply.  This  trend  of  reliance  on  plants 
outside  Massachusetts  is  also  detrimental  to  our  economy,  since  it 
creates  jobs  in  other  states  that  would  otherwise  benefit  Massachusetts 
workers. 


143 

1987]  SENATE  -  No.  2023  109 

RECOMMENDATION  IV 

DEPARTMENT  OF  PUBLIC  UTILITIES  TO  ESTABLISH  A 

FIVE-YEAR  SUPPLY  PLAN  WITHOUT  RELIANCE  ON 

THE  PILGRIM  PLANT 

The  Committee  has  found  that  the  Pilgrim  Nuclear  Generating 
Facility  at  Plymouth,  Massachusetts  has  suffered  from  serious  and 
continuous  mismanagement.  Although  significant  efforts  are  being 
made  by  its  owners  to  rectify  the  management  problems,  considerable 
uncertainty  remains  over  the  reUability  of  the  plant  to  contribute  to 
the  electric  supply  needs  of  the  Commonwealth. 

The  Committee  therefore  recommends  that  the  Department  of 
Public  Utilities  (DPU)  establish  a  five-year  plan  for  ensuring  adequate 
supply  without  consideration  of  the  electrical  production  of  Pilgrim 
plant.  Due  to  the  uncertain  future  of  Pilgrim,  the  DPU  should 
establish  a  supply  plan  for  the  Commonwealth  that  does  not  require 
any  dependence  on  the  Pilgrim  plant.  Such  plan  shall  include  a 
forecast  of  future  supply  and  demand  which  delineates  each  source 
of  power  and  its  location.  January  1,  1988  is  the  due  date  for  the 
implementation  of  the  initial  five-year  plan. 

The  Committee  recommends  that  in  determining  whether  to  restart 
the  Pilgrim  Nuclear  Power  Plant,  the  availability  of  sufficient  cost 
effective  and  safe  alternate  energy  resources  shall  be  taken  into 
consideration. 


144 

110  SENATE  —  No.  2023  [August 

RECOMMENDATION  V 


COMMITTEE  REVIEW  OF  THE  NUCLEAR  REGULATORY 
COMMISSION  (NRC)  SYSTEMATIC  ASSESSMENT  OF 

LICENSEE  PERFORMANCE  REPORT  (SALP)  AND 

RECOMMENDED  MEASURES  TO  CORRECT  SERIOUS 

FUNCTIONAL  DEFICIENCIES  AT  THE  PILGRIM  NUCLEAR 

GENERATING  FACILITY  AT  PLYMOUTH 


The  Pilgrim  nuclear  power  plant  has  a  well  documented,  and  well 
publicized,  history  of  problems.  This  history  has  called  into  question 
both  the  level  of  safety  when  Pilgrim  is  operating  and  Boston  Edison's 
ability  to  run  the  plant.  With  an  issue  as  emotional  as  nuclear  power, 
the  loss  of  public  confidence  must  be  addressed  in  addition  to  the 
actual  safety  problems. 

Massachusetts,  particularly  residents  of  Southeastern  Massachu- 
setts, have  every  right  to  demand  that  Pilgrim  be  one  of  the  best  run 
plants  in  the  country  rather  than  one  of  the  worst.  Clearly  the  initiative 
for  this  belongs  to  Boston  Edison.  Pilgrim  has  been  "off-line"  for  more 
than  a  year.  During  that  time  the  utility  has  undertaken  significant 
initiatives  to  improve  its  performance.  In  some  cases  they  have  taken 
a  lead  in  the  nuclear  industry  to  address  certain  problems.  More  work 
remains  to  be  done,  however,  and  how  effective  the  company  is  in 
its  work  will  have  to  be  judged  when  it  is  completed. 

This  is  neither  a  "pro-nuclear"  nor  an  "anti-nuclear"  report.  The 
committee  feels  that  where  there  are  problems,  they  must  be 
addressed,  prior  to  restart,  and  that  the  plant  should  not  operate  until 
all  major  deficiencies  are  corrected.  Individual  members  will  have 
their  own  views  on  nuclear  power  but  everyone  agreed  that  the 
overriding  issue  here  was  not  to  resolve  the  nuclear  debate  but  to 
address  the  problems  of  one  particular  plant. 

The  committee  heard  testimony  on  specific  operations  and  plant 
problems  from  Boston  Edison,  the  Nuclear  Regulatory  Commission, 
and  representatives  from  citizen  groups.  In  addition,  the  committee 
has  had  access  to  Public  Safety  Secretary  Charles  Barry's  report  to 
the  Governor  on  the  plant  and  volumes  of  NRC  reports. 


145 


1987]  SENATE  -  No.  2023  111 

To  try  and  identify  every  single  problem  and  the  appropriate 
solutions  would  be  beyond  the  committee's  capability  and 
jurisdiction.  The  sheer  number  of  technical  matters,  the  lack  of  expert 
staff,  and  the  debate  within  scientific  and  regulatory  circles  over  some 
issues  made  it  unrealistic  for  us  to  devise  the  specific  solutions  to  many 
particular  problems.  Likewise,  it  makes  little  sense  to  list  every  specific 
problem  since  it  would  make  more  difficult  our  aim  to  focus  public 
attention  on  the  most  substantive  problems. 

The  committee  does  feel,  though,  that  it  is  useful  for  the  Legislature 
to  summarize  the  patterns  of  problems  and  our  perceptions  of  the 
work  which  needs  to  be  done.  This,  we  hope,  will  not  only  focus 
greater  attention  on  the  major  problems  but  also  give  the  Legislature 
and  the  public  some  standard  by  which  we  can  measure  Edison's 
progress. 

The  NRC,  on  many  occasions,  has  claimed  it  will  force  Edison  to 
prove  significant  improvements  before  restart  is  allowed.  As  part  of 
their  process  they  will  develop  a  detailed  check  list  of  matters  requiring 
solutions.  The  committee  urges  the  NRC  to  include  our  concerns  as 
part  of  that  process.  If  addressed,  we  feel  plant  safety  will  be  enhanced 
and  public  confidence  raised. 

The  Nuclear  Regulatory  Commission  recently  issued  the  Pilgrim 
Systematic  Assessment  of  Licensee  Performance  (SALP)  for  the  15- 
month  period  of  November  1,  1985  through  January  31,  1987.  SALP 
is  a  comprehensive  assessment  of  the  plant  analyzed  into  twelve 
functional  areas.  The  report  identifies  recurring  programmatic 
weaknesses  in  five  functional  areas  including:  radiological  controls; 
surveillance;  fire  protection;  security;  and  assurance  of  quality. 

These  five  functional  areas  received  low  SALP  grades  of  3.  The 
NRC  rates  on  a  1,2,  and  3  basis  and  defines  a  3,  the  lowest  rating, 
as  follows: 

"Both  NRC  and  licensee  attention  should  be  increased. 
Licensee  management  attention  or  involvement  is  acceptable 
and  considered  nuclear  safety,  but  weaknesses  are  evident; 
licensee  resources  appear  to  be  strained  or  not  effectively  used 
so  that  minimally  satisfactory  performance  with  respect  to 
operational  safety  is  being  achieved." 
The  following  is  an  outline  of  the  problems  in  each  of  the  five 
functional  areas  as  reported  by  the  NRC,  followed  by  the  committee's 
recommendations. 


146 


112  SENATE  —  No.  2023  [August 

(1)  RADIOLOGICAL  CONTROL:  "This  assessment  covers 
radiation  protection,  effluent  monitoring  and  controls, 
radwaste  shipping  and  environmental  monitoring.  SALP 
found  that  the  licensee  made  numerous  improvements  in  the 
overall  quality  of  the  radiological  controls  program.  However, 
implementation  of  the  program  continues  to  be  weak.  When 
problems  with  program  implementation  or  adequacy  are 
identified,  corrective  actions  are  sometimes  not  adequate  or  not 
implemented  resulting  in  the  need  for  further  NRC  involve- 
ment. In  the  area  of  effluent  monitoring  and  control,  the 
licensee  implemented  the  new  effluent  technical  specifications 
in  a  generally  acceptable  manner,  however,  failure  to  take 
action  on  significant  long  standing  deficiencies  in  the 
environmental  Thermolumenescent  Dosimeters  (TLD) 
program  detracted  from  the  good  effort." 

COMMITTEE  RECOMMENDATIONS: 

a)  —  Aggressively  supervise  the  radiological  control  program. 

b)  —  Establish  and  implement  measures  to  verify  program  imple- 

mentation and  implement  corrective  actions  for  deficiencies. 

c)  —  Interactions  with  personnel  outside  the  radiological  group 

should  be  significantly  strengthened. 

d)  —  Continued  clean  up  of  plant  and  reduction  of  contaminated 

areas. 

e)  —  Strengthen  the  role  and  company  jurisdiction  of  radiation 

control  department  over  the  other  departments. 

f)  —  Exposure  histories  of  past  and  present  employees  and  con- 

tracted  workers   be  compiled,  continually   updated,   and 
reported  to  DPH  and  Nuclear  Facility  Safety  Division. 

g)  —  Improve  programs  for  replacement  of  thermoluminescent 

dosimeters. 

h)  —  Improve  training  of  employees  in  radiological  environmental 
technical  specifications. 

i)  —  Improve  control  and  accounting  of  special  nuclear  material 
under  one  gram. 

j)  —  Improved  access  control  to  high  radiation  areas. 

k)  —  Improved  inspection  of  vehicles  leaving  site  for  any  con- 
tamination. 


147 


1987]  SENATE  -  No.  2023  113 

(2)  SURVEILLANCE:  "Individual  surveillance  tests  were  well 
conducted  and  controlled.  The  response  to  recurring  local  leak 
rate  test  failures  was  also  positive.  However,  the  licensee  has 
been  slow  to  recognize  and  correct  weaknesses  in  the  control 
of  the  program  tests.  This  lack  of  progress  is  reflected  in  the 
large  number  of  surveillance-related  licensee  event  reports  and 
NRC  violations  issued  during  the  current  period.  The  control 
of  the  program  is  fragmented  and  not  always  effective  and 
appears  to  depend  more  on  historical  past  practice  then  in  a 
well-founded,  systematic  approach.  This  is  a  major  weakness 
that  must  be  corrected.  The  licensee's  measuring  and  test 
equipment  control  program  also  need  improvement." 

COMMITTEE  RECOMMENDATIONS: 

a) — Significant  site  and  corporate  management  attention  is  needed 

to  correct  deficiencies  in  this  area, 
b) — Place  a  single  qualified  individual  in  overall  charge  of  the 

surveillance  program. 

(3)  FIRE  PROTECTION:  "The  licensee  has  been  slow  to 
strengthen  the  fire  protection  program.  Problems  included 
inadequate  surveillance  procedures,  degraded  fire  barriers, 
inoperable  fire  protection  system  equipment,  and  poor  quality 
fire  brigade  training.  Although  action  has  been  taken  to  address 
these  concerns  the  program  has  suffered  from  a  chronic  lack 
of  attention  and  should  be  closely  monitored." 

COMMITTEE  RECOMMENDATIONS: 

a) — Significantly  reduce  the  amount  of  inoperable  fire  protection 

equipment  in  the  station, 
b) — System  for  assessing  priority  needs  and  timely  correction  of  any 

deficiencies  in  fire  barriers  and  protection  equipment, 
c) — Improved  supervision  and  training  of  fire  watchers, 
d) — Provision  for  independent  water  and  power  supplies, 
e) — Completion  of  all  Appendix  R  improvements, 
f) — System  to  control  combustible  material  on-site. 

(4)  SECURITY  AND  SAFEGUARDS:  "The  previous  SALP 
report  identified  serious  NRC  concerns  regarding  the  licensee's 


148 


114  SENATE  —  No.  2023  [August 

awareness  of,  and  attention  to,  NRC  physical  security 
objectives  and  the  need  for  additional  management  attention 
to,  and  support  of,  the  security  program  to  insure  that  the 
program  was  properly  implemented.  The  previous  SALP 
report  also  identified  NRC's  belief  that  the  licensee  had  initiated 
actions  to  resolve  those  concerns  and  that  the  security  program 
was  receiving  increased  management  attention.  However, 
shortly  after  the  beginning  of  this  assessment  period,  it  became 
apparent  to  the  NRC  that,  due  to  the  number  and  complexity 
of  the  identified  problems  and  some  other  problems  which  were 
then  surfaced,  far  more  extensive  management  attention  and 
resources  would  be  required.  As  evidenced  during  this 
assessment  period,  the  need  for  additional  attention  and 
resources  by  the  licensee  continued  until  late  in  this  assessment 
period.  As  a  result,  little  physical  progress  toward  improving 
the  program  was  accomplished  by  the  licensee  during  the 
period." 

COMMITTEE  RECOMMENDATIONS: 

a) — High  level  corporate  and  site  management  attention  to  the 
recently  established  priority  level  for  the  security  program 
upgrade  should  continue  in  order  to  implement  commitments 
and  develop  an  effective  program. 

b) — NRC/ Boston  Edison  review  of  relationship  of  contracted 
security  force  over  Boston  Edison  and  other  contracted 
employees.  Does  Security  have  adequate  power  to  control 
plant  personnel  and  question  employee  activities? 

c) — Develop  and  implement  effective  program  to  eliminate  any 
presence  or  use  of  alcohol  and  drugs. 

d) — Elimination  of  any  violations  or  weaknesses  in  security 
barriers. 

(5)  ASSURANCE  OF  QUALITY:  "Although  the  licensee  has 
exhibited  good  performance  in  certain  activities  such  as  outage 
control  and  engineering  and  has  displayed  initiative  in  its  safety 
enhancement  program,  significant  deficiencies  still  were  found 
to  exist  in  radiological  controls,  surveillance,  fire  protection 
and   security.    Some   of  these   deficiencies   have   existed 


149 


1987]  SENATE  -  No.  2023  115 

throughout  the  period  and  have  been  identified  in  previous 
SALP  reviews,  and  by  the  Hcensee's  own  quahty  assurance 
organization.  The  ambiguity  of  the  site  organizational  structure 
and  the  instabihty  in  the  corporate  and  site  management  team 
have  resulted  in  the  licensee's  inability  to  address  and  resolve 
these  long-standing  problems  without  repeated  prompting  and 
overview  by  NRC.  Senior  corporate  management  was  slow  in 
confronting  the  problems  and  in  implementing  corrective 
actions.  Late  in  this  assessment  period  and  immediately 
following  it,  the  licensee  took  steps  to  address  its  organization 
weaknesses.  However,  the  effectiveness  of  these  efforts  in 
improving  the  licensee's  performance  remains  a  matter  of 
continuing  NRC  interest  and  concern." 

COMMITTEE  RECOMMENDATIONS: 

a) — Continue  senior  management  attention  to  identify  problems  to 

ensure  that  they  are  promptly  and  effectively  resolved, 
b) — Improve  tests  and  surveillance  of  equipment  program, 
c) — Greater   authority   of  quality   control   staff   over   other 

departments  to  resolve  any  conflicts  between  procedures  and 

personnel  in  different  operation  groups, 
d) — Improve  training  and  supervision  over  contract  workers, 
e) — Improvements  in  visual  surveillance  system  to  properly  identify 

and  describe  deficiencies, 
f) — Improve  training,  testing  and  requalification  of  personnel. 

(6)  PLANT/ EQUIPMENT 

COMMITTEE  RECOMMENDATIONS: 

a) — Maintenance  requests  back  log  be  eliminated. 

b) — Complete  review  of  maintenance  and  testing  schedules  with  all 

incomplete   testing   being   finished    and    any   deficiencies 

corrected, 
c) — Identification  and  repair  of  Main  Stream  Isolation  Valve  and 

RHR  pumps  which  caused  initial  spurious  scram  which  closed 

the  plant, 
d) — NRC  investigation  and  public  explanation  of  recent  reports  of 

deficiencies  in  certain  General   Electric  reactors,   including 

Pilgrim.   The   public   should   be   informed   of  the   possible 


150 


116  SENATE  -  No.  2023  [August 

problems  and  any  action  taken  by  General  Electric  or  Boston 
Edison  which  has  corrected  these  deficiencies.  All  uncorrected 
problems  should  be  corrected, 
e)^ — The  NRC  and  General  Electric  should  also  make  available  to 
the  public  the  General  Electric  report. 

(7)  GENERAL  MANAGEMENT  CONCERNS:  The  following  are 
recommendations  which  address  general  management  areas 
which  the  committee  feels  need  review. 

COMMITTEE  RECOMMENDATIONS: 

a) — Staff  vacancies  in  key  areas  should  be  filled  to  adequate  levels, 
b) — Demonstration  that  the  new  programs,  divisions  and  personnel 

can  actually  perform  as  planned, 
c) — Resolution   of  inter-group   conflicts   and   clearer   lines   of 

authority   for   safety,    ALARA   (As   low   as   reasonably 

achievable),  and  fire  protection  personnel  over  other  divisions, 
d) — Review   and    planning   of  transition   from   outage   and 

maintenance  mode  to  on-line  operation  so  that  they  are 

prepared  if  restart  is  approved. 

(8)  REACTOR  CONTAINMENT:  In  its  most  recent  SALP  report 
the  NRC  noted  the  following:  "Plant  hardware  changes  were 
also  impressive,  particularly  the  planned  Mark  I  containment 
enhancements.  The  modifications  go  considerably  beyond  NRC 
recommendations  and  show  a  concern  for  nuclear  safety." 
Nevertheless,  serious  concerns  have  been  raised,  both  inside  and 
outside  of  the  NRC,  about  the  Mark  I  containment  and  its 
possible  failure  in  the  event  of  a  major  accident.  The  Committee 
has  sent  a  letter  to  Boston  Edison  seeking  more  information  on 
exactly  what  work  is  planned  to  enhance  the  containment 
system.  In  addition,  the  committee  strongly  urges  that  prior  to 
restart  the  NRC,  the  state,  and  Boston  Edison  shall  hold  a  public 
hearing  on: 

a)  The  possible  defects  or  weaknesses  of  the  Mark  I  containment; 

b)  the  work  planned  by  Boston  Edison  to  improve  it; 

c)  the  schedule  for  that  work; 

d)  NRC  studies  and  others  done  on  the  integrity  or  possible  failure 
of  the  containment  in  the  event  of  a  major  accident.  The 
containment  is  such  a  crucial  safety  feature  in  nuclear  plants  that 


151 


1987]  SENATE  -  No.  2023  117 

all  work  to  strengthen  any  weaknesses  must  be  completed  prior 
to  restart, 
e)  An  evaluation  of  any  additional  safety  features  such  as  filtered 
venting  of  the  containment,  molten  core  barriers,  underground 
residual  heat  removal  system,  and  a  secondary  steel  containment. 

(9)  STANDBY  GAS  TREATMENT  SYSTEM:  Prior  to  refueling 
the  problems  identified  with  the  Standby  Gas  Treatment  System 
should  be  corrected, 
(10)  DECOMMISSIONING  PLAN:  It  is  unclear  what  happens  to 
the  plant  and  storage  of  radioactive  waste  when  the  plant  is 
permanently  closed.  The  questions  of  the  cost  involved 
decommissioning,  the  impact  on  Plymouth  taxes,  waste  storage, 
security,  and  dismantling  or  "seaUng"  of  the  reactor  building  are 
of  great  concern  to  area  residents.  The  NRC,  the  state  and  Boston 
Edison  should  develop  decommissioning  plans,  well  before  a 
scheduled  closing,  to  answer  these  and  other  questions. 

The  Committee  after  intensive  review  of  the  NRC  SALP  report 
recommends  the  Boston  Edison  Company  immediately  take  positive 
action  on  all  of  the  above  recommendations.  Boston  Edison  should 
improve  all  of  the  categories  which  received  grades  of  category  3  on 
the  most  recent  SALP  report.  The  two  primary  causes  for  the  NRC's 
category  3  findings  were  slowness  in  making  improvements  and  lack 
of  management  attention.  These  problems  should  be  resolved  so  that 
none  of  the  functional  areas  maintains  a  category  3  grade.  It  is 
imperative  that  all  improvements  are  completed  before  action  is  taken 
to  restart  the  Pilgrim  Nuclear  Power  generating  facility  at  Plymouth. 


152 

118  SENATE  -  No.  2023  [August 

RECOMMENDATION  VI 

IMPROVED  EMERGENCY  PREPAREDNESS  PLANNING 

Emergency  preparedness  is  the  last  layer  of  protection  for  public 
health  and  safety  in  the  event  of  an  accident  at  a  nuclear  plant.  Until 
recently,  emergency  planning  seems  to  have  been  perceived  more  as 
a  regulatory  requirement  than  a  form  of  protection  which  might  be 
called  into  use.  As  public  concern  over  nuclear  plants  has  increased 
over  the  past  year,  so  has  emergency  planning  come  under  greater 
scrutiny. 

This  scrutiny  has  found  the  obvious  current  emergency  planning 
is  inadequate.  The  primary  responsibility  to  correct  these  inadequacies 
rests  with  the  state.  Working  with  federal  officials,  local  officials,  and 
the  utility  the  state  must  take  immediate  action  to  develop  plans  that 
are  more  realistic  and  dependable. 

The  federal  government  has  reserved  to  itself  most  powers  dealing 
with  nuclear  power  plants.  The  state,  however,  is  left  with  almost  total 
responsibility  in  protecting  the  public  should  an  accident  ever  happen. 
While  this  may  be  jurisdictionally  awkward  there  is  no  substitute  for 
state  and  local  planning.  Local  and  state  officials  are  the  most 
qualified  to  prepare  and  implement  emergency  plans. 

It  is  unacceptable  to  this  committee  for  a  private  utility  or  federal 
agency  to  try  and  fulfill  or  usurp  state  and  local  responsibility.  The 
committee  feels  that  prior  to  restart  emergency  plans  must  first  be 
reviewed  and  approved  by  town  officials,  in  the  Emergency  Planning 
Zone  (EPZ)  communities,  and  by  the  state.  Nuclear  Regulatory 
Commission  (NRC),  Federal  Emergency  Management  Agency 
(FEMA),  Boston  Edison,  the  State,  and  towns  should  work  on  a 
schedule  to  coordinate  the  review  and  decision  on  whether  to  approve, 
prior  to  restart. 

There  is  growing  debate  over  how  far  states  can  use  the  planning 
approval  requirement  as  a  means  of  preventing  a  new  plant  from  being 
licensed  or  of  closing  a  licensed  plant,  if  a  state  does  not  believe  an 
emergency  response  plan  can  adequately  protect  the  public  health  and 
safety.  It  appears  that  the  NRC,  Congress,  and  undoubtedly  the  courts 
will  be  reviewing  this  issue  as  more  states  withhold  approvals. 

The  state  should  pursue  two  courses.  State  and  local  governments 
should  develop  the  strongest  possible  emergency  plans.  The  public's 


153 


1987]  SENATE  -  No.  2023  119 

health  and  safety  demands  nothing  less.  If,  after  those  plans  are 
developed,  the  Governor  feels  they  are  still  inadequate  then  he  may 
withhold  approval. 

The  committee  heard  testimony  from  the  Department  of  Public 
Safety  about  the  need  to  plan  beyond  a  set  limit  of  ten  miles.  The 
Department  stressed,  though,  that  with  deficiencies  in  current  ten  mile 
planning  any  work  beyond  the  ten  mile  zone  should  not  deflect  any 
attention  from  the  communities  within  the  zone.  Communities  closest 
to  the  plant  require  a  higher  level  of  planning  than  communities 
farther  away.  The  Department  also  testified  that  while  Civil  Defense 
is  the  primary  agency  for  dealing  with  emergencies  other  divisions  are 
involved  such  as  the  National  Guard,  Public  Safety,  and  Public 
Health.  The  Department  noted  that  coordination  between  state 
agencies  for  nuclear  emergency  planning  needs  to  be  improved. 

Local  Civil  Defense  officials  from  several  towns  in  the  EPZ  testified 
before  the  committee.  Their  concerns  included: 

A)  Lack  of  a  reception/ decontamination  area; 

B)  A  need  for  greater  technical  and  material  assistance  from  the 
state  and  utility; 

C)  Criticism  that  the  plans  lacked  specific  written  agreements  with 
parties  which  might  be  involved  with  an  emergency,  such  as  bus 
companies  and  hospitals; 

D)  A  need  to  plan  for  regional  school  systems  in  which  students 
come  from  one  but  not  all  towns  within  the  EPZ;  and 

E)  The  need  for  more  inter-community  planning  in  order  to  have 
a  coordinated  regional  plan. 

The  town  of  Plymouth  has  created  its  own  local  advisory  committee 
on  nuclear  matters.  That  committee  has  thoroughly  reviewed  the 
town's  emergency  response  plan.  Their  report  has  been  made  available 
to  the  committee  and  demonstrates  the  kind  of  detailed  planning 
necessary  for  a  strong  response  plan.  It  also  demonstrates  the 
indispensable  role  of  local  governments  in  developing  plans.  Many 
of  their  recommendations  would  be  helpful  to  other  towns.  Their 
report  is  included  (see  Appendix  9). 


154 


120  SENATE  -  No.  2023  [August 

While  primary  responsibility  for  planning  rests  with  state  and  local 
officials  there  is  necessary  assistance  which  should  come  from  the 
utility.  This  includes  technical  advice  as  well  as  material  support 
accepted  by  the  state,  a  county,  or  a  town.  The  committee  feels  that 
this  assistance  should  be  paid  for  through  utility  assessments  which 
will  be  passed  on  to  utility  ratepayers  rather  than  all  taxpayers. 

Specific  improvements  to  the  emergency  plans  need  to  come  from 
the  utility,  towns  and  state.  The  committee  recommends  the  following 
improvements: 

BOSTON  EDISON  PLANNING  ASSISTANCE: 

(1)  Boston  Edison  Company  should  provide  updated  and  accurate 
Evacuation  Time  Estimates  under  a  wide  variety  of  accident 
scenarios.  This  will  enable  state  and  local  officials  to  better  plan 
traffic  management  in  the  event  of  an  emergency. 

(2)  Identification,  notification  and  workable  evacuation  plans  for 
mobility  impaired  and  individuals  who  will  have  difficulty  being 
notified  of  an  emergency  or  in  being  familiar  with  the  emergency 
response  procedure.  Such  individuals  include  the  physically 
disabled,  those  depending  on  public  transportation,  the  hard 
of  hearing  and  those  who  speak  limited  English.  Greater 
attention  to  these  individuals  will  help  ensure  that  no  one  is 
excluded  from  the  planning. 

BOSTON  EDISON  EQUIPMENT: 

(1)  Boston  Edison  should  improve  Public  Alert  Systems  including 
testing.  Sirens  should  be  tested  more  frequently  with  improved 
monitoring  and  identification  of  individual  siren  deficiencies. 
Siren  systems  should  be  audible  in  the  entire  EPZ,  and  loud 
enough  to  be  heard  in  buildings  with  closed  windows.  In 
addition,  this  system  should  be  supplemented  with  an  adequate 
number  of  loudspeaker  equipped  vehicles. 

(2)  Review  and  supply  of  needed  equipment  for  shelters  and 
reception  areas  for  evacuations.  During  summer  months  local 
population  swells,  increasing  the  need  for  sheltering  areas  for 
non-resident  visitors. 


155 


1987]  SENATE  -  No.  2023  121 

(3)  Provide  greater  information  in  the  event  of  an  emergency. 
During  an  incident,  people  may  not  have  written  information 
on  hand  about  procedures  to  be  followed.  This- is  particularly 
true  for  non-residents.  Printed  material  with  procedures  for  an 
emergency  should  be  pre-printed  for  quick  distribution  in  group 
shelters,  relocation  areas,  hospitals,  public  transportation,  and 
through  school  children  during  an  emergency. 

(4)  Boston  Edison  should  update  the  Nuclear  Energy  Pamphlet  to 
impress  upon  the  public  the  importance  of  following  official 
instructions.  Necessary  information  should  include  maps, 
location  of  public  shelters,  locations  of  public  transportation 
facilities,  Emergency  Broadcast  System  affiliates,  traffic  routes, 
reception  areas  and  personal  safety  precautions. 

EMERGENCY  PLANNING  ZONE  (EPZ): 

(1)  Clarify  that  when  any  part  of  a  town  lies  within  an  EPZ,  the 
entire  town  shall  be  part  of  the  EPZ.  Planning  and  resources 
for  these  towns  will  have  to  be  upgraded. 

(2)  Clarify  planning  for  regional  schools  which  have  students  from 
at  least  one,  but  not  all,  towns  in  the  school  system  which  are 
part  of  an  EPZ. 

(3)  Clarify  authority  of  Public  Safety  to  plan  for  a  radiological 
emergency  beyond  a  10  mile  EPZ.  (See  Recommendation  I  — 
Division  of  Nuclear  Facility  Safety) 

(4)  Evacuation  time  estimates  and  traffic  control  plans  should  be 
based  on  evacuations  of  people  within  the  EPZ  to  centers  well 
beyond  the  10  mile  zone  and  should  anticipate  secondary  or 
shadow  evacuations. 

STATE  PLANNING: 

(1)  Increase  state  assistance  to  local  planners.  This  should  include 
technical  assistance  as  well  as  financial  assistance  for  local  use. 
The  goal  should  be  coordinated  regional  planning  as  well  as 
strengthened  local  plans. 


156 

122  SENATE  -  No.  2023  [August 

(2)  Inventory  and  where  necessary  create  adequate  local  shelters 
to  protect  non-resident  visitors  in  the  event  of  emergencies 
which  may  not  require  e-vacuation. 

(3)  Identify  area  medical  services,  hospitals  and  medical  personnel 
available  for  use  outside  of  the  EPZs.  Also  evaluate  any 
additional  services  and  supplies  which  may  be  necessary  to  serve 
EPZ  population  in  the  event  of  an  emergency,  including 
emergency  treatment  facilities  and  training  of  medical 
personnel. 

(4)  The  state  and  towns  should  participate  in  appropriate 
emergency  drills. 

(5)  Specific  planning  shall  be  developed  for  emergency  notification, 
evacuation  planning,  and  traffic  control  planning  should  be 
imposed  in  areas  outside  of  an  EPZ  which  pose  unique 
problems,  e.g.:  Cape  Code  and  the  Islands. 

(6)  Inventory  of  available  buses,  ambulances  and  handicapped/ 
elderly  vans,  to  assist  in  an  evacuation.  Develop  an  inventory 
of  service  stations  and  towing  operations  to  be  available  along 
evacuation  routes. 

(7)  Supervise  planning  by  towns,  ensure  a  coordinated,  regional 
plan,  and  ensure  cooperation  between  the  utilities  and  area 
towns. 

(8)  Identify  and  designate  adequate  reception  and  decontamination 
centers  and  ensure  the  availability  of  adequate  supplies  and 
equipment. 

(9)  Ensure  appropriate  annual  review  and  publication  of  plans 
working  with  the  utilities,  towns  and  Federal  Emergency 
Management  Agency  (FEMA). 

(10)  Evaluate  and  where  necessary  correct  effectiveness  of 
notification  and  communication  system  between  state  and  local 
officials. 


157 


1987]  SENATE  -  No.  2023  123 

(11)  Identification,  notification  and  workable  evacuation  plans  for 
people  in  all  institutional  facilities  —  such  as  hospitals,  nursing 
homes,  schools  and  prisons  —  inside  the  EPZ. 

(12)  Contractual  agreements  for  the  above  services  where 
appropriate  should  be  made  to  avoid  any  erroneous 
assumptions  of  transportation  in  the  event  of  an  evacuation. 

LOCAL  PLANNING: 

(1)  Each  town  in  an  EPZ  should  consider  establishing  a 
Radiological  Emergency  Response  Plan  Committee  to  review 
matters  pertaining  to  emergency  response  planning. 

(2)  Local  plans  need  more  thorough  documentation  and  letters  of 
agreement  between  involved  parties  to  ensure  clear  lines  of 
responsibilities  in  the  event  of  an  emergency. 

(3)  Local  officials  should  inventory  local  planning  needs, 
equipment  and  resources  which  can  be  provided  by  the 
Division  of  Nuclear  Facility  Safety  or  the  utilities. 

(4)  In  addition  to  plans  for  their  own  communities,  local  officials 
should  work  closely  with  neighboring  communities  to  ensure 
workable  regional  planning. 

(5)  Each  town  in  an  EPZ  should  establish  plans  for  informing  non- 
residents of  procedures  to  be  followed  in  the  event  of  an 
emergency. 

The  state  and  utility  have  been  ineffectual  and  too  informal  in 
developing  adequate  emergency  response  plans.  The  committee, 
therefore,  finds: 

A)  The  Pilgrim  Nuclear  Power  Plant  should  not  restart  until,  and 
unless,  an  emergency  preparedness  plan,  including  evacuation, 
has  been  approved  by  the  Selectmen  in  the  EPZ  communities 
and  by  the  Governor; 


158 


124  SENATE  -  No.  2023  [August 

B)  Federal,  state,  and  local  officials  and  the  utility  should 
coordinate  actions  in  order  to  reach  a  decision  on  whether  to 
approve  emergency  response  plans  prior  to  restart. 

C)  The  cost  of  emergency  planning  should  not  be  borne  by  all 
taxpayers,  but  financed  through  utility  assessments. 


159 

Mr.  FoRMAN.  I,  frankly,  don't  see  the  problem  with  giving  the 
States  the  power  to  decide  whether  or  not  they  have  nuclear  power 
plants.  I  fully  understand  and  accept  the  rationale  that  States  and 
local  governments  shouldn't  necessarily  regulate  nuclear  power 
plants  in  monitoring  them  in  terms  of  their  operation  as  well  as  in 
terms  of  the  conditions  of  health  effects.  But  I  have  a  problem  with 
the  federal  government  prohibiting  States  from  deciding  whether 
or  not  they  want  plants  in  their  State. 

I'm  also  troubled  by  the  fact  that  the  only  straw  that  we  seem  to 
be  grabbing  at  in  trying  to  create  some  State  authority  is  the  use  of 
emergency  preparedness  and  withdrawal  of  State  approval  or 
denial  of  State  approval  for  emergency  plans.  I  think  that  actually 
could  lead  to  some  public  safety  risks,  depending  on  how  the  court 
and  the  NRC  interpret  the  State  authority.  So  I  would  urge  Con- 
gress and  the  administration  to  consider  some  outright  approval  to 
States  across  the  country,  not  just  because  of  Pilgrim,  but  in  terms 
of  State  authority  and  Federal. 

The  Chairman.  What  do  we  do  on  nuclear  waste?  Do  we  give  the 
States  authority  to  reject  that? 

Mr.  Form  AN.  We  keep  the  pressure  on  Congress  and  the  adminis- 
tration to  pick  a  site  out  in  Nevada.  [Laughter.] 

The  Chairman.  Do  we  give  those  States  the  power  to  reject? 

Mr.  Forman.  I  don't  think  we  can. 

The  Chairman.  First  of  all,  we  might  just  make  it  normal  proce- 
dure if  a  State  is  going  to  use  nuclear  power,  let  them  take  the  risk 
in  terms  of  storing  it. 

[Applause.] 

Mr.  Forman.  If  I  can  suggest  something  in  response  to  that.  We 
deal  with  issues  in  this  State  over  low  level  waste,  solid  waste  and 
we  run  into  those  siting  problems.  I  think  that  you  can  clearly 
infer  a  distinction  between  the  State's  willingness  or  desire  to  have 
an  operating  plant  sited  in  their  State  as  opposed  to  national 
public  health  interest  of  finding  a  disposal  site  which  is  en\dron- 
mentally  sound. 

The  Chairman.  I  think  that's  right. 

Mr.  Alexander.  I  would  say,  first  of  all,  that  the  legal  issue  of 
the  State's  problem  is  still  up  in  the  air.  You  know  Governor  Ce- 
leste of  Ohio  actually  withdrew  the  Emergency  Response  Plan  for 
nuclear  powerplants  there  until  the  Commission  could  take  an- 
other look  at  it,  and  that's  in  the  court  as  to  whether  or  not  he  has 
that  authority  or  not. 

So  I  would  first  say  that  it  is  still  unclear  whether  Massachusetts 
can  say,  "Well,  we're  not  going  to  allow  Pilgrim  to  operate  because 
we  don't  feel  that  the  emergency  response  plan  is  adequate,"  but  I 
do  think  it  would  be  worthwhile  to  allow  Congress  to  allow  States 
the  ability  to  regulate  nuclear  power  to  the  extent  that  if  Congress 
has  a  standard,  that  States  should  be  allowed  to  have  standards 
that  are  at  least  as  tough  as  those  of  the  Federal  standards;  that 
way  you  are  not  going  to  have  people  who  might  not  be  as  expert 
weakening  the  standards.  On  the  other  hand,  if  the  States  should 
have  proper  standards,  it  should  be  allowed  to  do  so. 

The  Chairman.  Senator  Golden,  we  very  much  acknowledge  the 
very  important  contributions  you  have  made  in  terms  of  raising  so 


160 

many  of  these  issues.  I'm  grateful  for  your  presence  here  this 
evening. 

Let  me  ask  you,  given  what  you  have  said  about  the  evacuation 
plans,  do  you  think  it  is  possible  to  develop  an  effective  evacuation 
plan  at  this  point? 

Mr.  Golden.  I  believe  it  would  be  very  difficult.  Senator,  to  de- 
velop an  effective  evacuation  plan.  I  believe,  given  the  limited 
transportation  routes  in  this  area,  we've  lost  effectively  180  degrees 
because  the  plant  is  on  the  shoreline,  and  because  of  the  limited 
north,  south,  east  and  west  transportation  access  that  we  have  to 
the  site,  I  believe  that  if  the  plant  was  to  restart,  it  would  require 
significant  sheltering  plans  with  shelters  that  were  properly 
equipped  and  those  that  could  withstand  the  pressure  and  stress  of 
the  public's  access  to  them.  Right  now,  we  don't  have  that.  There 
are  people  who  are  being  sheltered  in  2-foot  crawl  spaces,  according 
to  the  existing  plan,  and  in  buildings  that  don't  exist  any  more.  So 
we  need  a  lot  of  input 

If  I  could  just  briefly  respond.  Senator,  to  your  question  about 
access  to  the  public.  I  would  like  to  see  Congress  change  the 
Atomic  Energy  Act  and  permit  the  Governor  of  a  State,  as  a 
matter  of  right,  to  demand  a  show  cause  petition.  Our  Governor 
has  requested  a  show  cause  hearing.  I  believe  each  Governor  of 
each  State  should  have  that  right,  at  legist,  and  that  would  open 
the  public  process.  The  public  process  could  also  be  opened  up,  I 
believe,  by  enabling  local  government,  as  well  as  State  government, 
a  role  in  the  formulation  and  implementation  of  these  plans,  and 
with  that  role,  the  veto  power  over  the  plants  for  their  own  com- 
munities because  they  do  know  their  communities  well. 

The  Chairman.  Let  me  ask  just  quickly  and  then  we  can  move 
on.  You  stressed  in  your  statements  you've  made  on  this  issue  in 
other  forums,  the  importance  of  development  of  cheap  energy.  Are 
your  views  tonight  consistent  with  what  you  would  like  to  see  in 
terms  of  development  of  cheaper  energy? 

Mr.  Golden.  Yes,  Mr.  Chairman.  One  form  of  cheap  energy  pro- 
duction is  energy  conservation.  As  Rachel  Shimshak  from 
MASSPIRG  has  indicated,  this  company,  through  its  own  commit- 
tee, the  Hogan  committee,  it  was  chaired  and  directed  by  the 
United  States — former  U.S.  Senator  Saunders,  indicated  this  com- 
pany by  the  year  2000  saved  a  thousand  megawatts  of  power.  The 
company  in  response  would  request  a  proposal,  a  proposal  submit- 
ted in  excess  of  2,000  megawatts. 

All  of  that  power  would  provide,  I  believe,  a  cheap  alternative  to 
Pilgrim.  Given  the  fact  especially,  Mr.  Chairman,  that  since  April 
of  1986,  when  this  plant  was  shut  down,  there  has  been  expendi- 
tures totaling  over  $300  million  for  replacement  power  and  con- 
struction cost  on  this  plant.  That's  $300  million,  and  we're  not  any 
better  off  today  with  all  that  expenditure  than  we  were  20  months 
ago  when  the  plant  was  shut  down. 

The  Chairman.  Just  quickly,  Mr.  Alexander. 

Mr.  Alexander.  Thank  you.  Senator.  Certainly  the  cheapest 
form  of  power  is  conservation — where  we  don't  have  to  produce 
more  power.  An  example  of  conservation's  potential  is  the  Appli- 
ance Efficiency  Law  that  was  passed  here  in  Massachusetts.  This 
one  law  alone — by  only  allowing  stores  to  sell  energy-efficient  re- 


161 

frigerators — will  each  year  by  the  year  2000  save  us  an  amount  of 
power  equivalent  to  approximately  half  of  the  output  of  the  Pil- 
grim nuclear  power  plant.  One  simple  law  will  do  that.  The  Feder- 
al appliance  efficiency  law  is  going  to  save  the  equivalent  amount 
of  energy  as  about  23  nuclear  powerplants. 

It  also  needs  to  be  said  that  if  you  do  need  new  sources  of  power, 
it  makes  much  more  sense  to  have  in  place  small  generating  facili- 
ties that  are  relatively  local,  so  that  if  one,  for  instance,  has  an 
outage,  we  don't  all  of  a  sudden  face  the  kind  of  crisis  that  the 
New  England  power  pool  suggests  we're  going  to  have,  when  a 
couple  of  nuclear  powerplants  are  down  for  total  plant  mainte- 
nance. 

Mr.  FoRMAN.  I  have  a  slightly  different  view  on  the  importance 
of  conservation.  Any  sound  energy  policy  obviously  has  to  include 
conservation,  but  I  think  that  we  are  somewhat  misguided  in  as- 
suming that  in  a  region  that  is  growing,  an  economy  that  is  grow- 
ing £ind  dependent  on  energy,  that  we're  going  to  survive  for  too 
long  in  the  future  simply  by  conserving.  There  is  a  finite  limit  on 
how  much  we  can  conserve  £ind  continue  to  grow. 

Mr.  Alexander.  I  think  one  of  the  great  problems  we  have  in 
this  country  is  that  we  don't  have  a  national  energy  policy  that 
anyone  can  identify,  and  from  what  I  can  tell,  the  State  doesn't 
either.  I  don't  know  of  any  states  that  do  have  a  policy,  and  that's 
a  real  problem.  It  doesn't  have  to  be  based  on  nuclear.  Clearly,  we 
can  have  energy  policy  without  it,  but  both  the  State  and  the  coun- 
try, we  need  some  sound  energy  policy  that  will  go  way  beyond 
conservation  and  talks  about  generation  of  new  power  sources  for 
growing  areas,  such  as  a  fossil  plant  in  Weymouth.  [Applause.] 

The  Chairman.  Thank  you  very  much.  I  want  to  first  of  all 
thank  you,  and  the  people  of  Plymouth,  through  you,  for  all  of 
their  willingness  and  hospitality  this  evening  and  for  helping  us  so 
much  with  this  hearing. 

I  have  just  one  point.  As  I  understand  your  testimony,  the  Plym- 
outh Board  of  Selectmen  has  made  their  objections  known  to  the 
NRC  concerning  restarting  of  the  plant  without  an  adequate  pre- 
paredness plan.  I  would  like  to  ask  you  how  the  NRC  has  respond- 
ed to  your  concern. 

Mr.  Malaguti.  We  have  constant  communication  with  the  NRC. 
We  had  indications  that  they  are  receptive  to  our  comments. 

The  Chairman.  Did  they  say  they  wouldn't  restart  until  they 
worked  out  the  new  evacuation  plan? 

Mr.  Malaguti.  No,  sir.  They  have  not. 

The  Chairman.  Do  you  think  they  should? 

Mr.  Malaguti.  Absolutely. 

The  Chairman.  OK.  Ms.  Shimshak,  we'll  include  all  of  the 
MASSPIRG  studies  in  the  record.  The  first  is  the  1983  report  enti- 
tled "Blueprint  for  Chaos,"  and  then  there  is  the  1987  report  enti- 
tled "No  Exit,"  and  finally  there  is  the  other  1987  report  entitled 
"Nuclear  Lemon."  All  those  will  be  included. 

[The  documents  referred  to  above  follow:] 


162 


■-*:^Ti^. ,;',', 


^^m^-i 


Boston,  m  OZU^ 
617,423-1795   ' 


THE  MASSACHUSETTS  PUDLIC  IfUEREST  RESEARCH  GROUP 


163 


Acknowledgments 

Glenn  Lamb  and  Carrie  Wehllng,  MASSPIRG  summer  interns,  provided 

» 

subBtantial  assistance  with  data  collection  and  telephone  surveys  of 
special  institutions  in  the  Emergency  Planning  Zone.  Telephone  surveys 
of  residents  were  conducted  by  Eric  Dohlman,  Jennifer  Krouse,  Paula  Lenzl, 
Carrie  Wehllng,  Arthur  Rounds,  Claudia  Basso,  Wyatfe  Moor,  Wayne  Stec, 
Leslie  Stebbins,  and  Robert  Scudder.   Thanks  also  to  Nonna  Giunta  for  her 
administrative  assistance  and  to  Matthew  Mattingly  for  Illustrations. 

Special  thanks  are  also  due  Jack  Dolan  and  Frank  Willard  of  the 
Mass.  Civil  Defense  Agency  who  have  given  generously  of  their  valuable 
time  to  discuss  the  emergency  plans  at  length. 

Consultation  was  also  provided  by  "Doc"  Mark  Boehnert,  M.D., 
Steven  Sholly  of  the  Union  of  Concerned  Scientists,  Kathleen  Welch  of 
NYPIRG,  and  Richard  Udell  of  the  Oversight  &  Investigations  Subcommittee 
of  the  Committee  on  Interior  and  Insular  Affairs  of  the  U.S.  House  of 
Representatives. 

Thank  you  all  for  your  contributions  to  improving  emergency 

preparedness  at  Pilgrim. 

Michael  Ernst 
July  20,  1983 


164 


TABLE  OF  CONTENTS 

Page 

EXECUTIVE  SUMMARY 

EMERGENCY  PLANNING:   AN  OVERVIEW   1 

The  Need  for  Emergency  Planning   1 

Emergency  Planning  in  Massachusetts   3 

I.  *   THE  EMERGENCY  PLANNING  ZONE 7 

II.  ADVANCE  INTORMATION  TO  THE  PUBLIC    10 

III.  NOTIFICATION  DURING  AN  ACCIDENT 16 

Notifying  Authorities  16 

Notifying  the  Public:   Sirens  17 

Notifying  the  Public:   Emergency  Broadcast  System  ...  19 

Notifying  the  Deaf 20 

IV.  EVACUATION  PLANS.  SHELTERING,  AND  OTHER  PREPARATIONS   ...  22 

The  Decision  to  Evacuate 22 

Special  Population  Groups  .  27 

Cape  Cod 32 

Reception  Facilities  33 

Medical  Facilities   35 

Sheltering 36 

Emergency  Drills   39 

CONCLUSION ^1 

FOOTNOTES   ^3 

APPENDICES 

A.  Telephone  Survey  of  Residents 

B.  Survey  of  Major  Campgrounds 

C.  Survey  of  Local  Civil  Defense  Directors 

D.  Survey  of  Correctional  Facilities 

E.  Survey  of  Ambulance  Services 

F.  Survey  of  Nursing  Homes 

G.  Survey  of  Hospitals 


165 


EXECUTIVE  SUMMARY 


As  a  result  of  the  partial  core  meltdown  at  Three  Mile  Island,  the        \ 
Nuclear  Regulatory  Commission  (NRC)  was  forced  to  concede  that  dangerous 
quantities  of  radioactivity  could  escape  from  nuclear  power  reactors  and 
that  workable  evacuation  plans  were  necessary  to  protect  the  public.   A 
government  study  estimated  that  a  very  serious  meltdown  at  Pllgtla  Nuclear 
Power  Station  in  Plymouth,  MA,  could  kill  3,000  people.  Injure  30,000 
more,  and  cause  23,000  fatal  cancers. 

Effective  emergency  planning  and  preparedness  can  greatly  reduce 
radiation  exposure  because  some  reactor  meltdowns  would  take  many  hours 
to  develop  and  provide  ample  time  for  evacuation.   For  faster  developing 
meltdowns,  proper  sheltering  with  breathing  filters  and  a  drug  to  protect 
the  thyroid  glands  would  reduce  the  health  consequences. 

Unfortunately,  more  than  two  years  after  the  NRC  deadline,  the 
Pilgrim  emergency  response  plans  remain  woefully  inadequate  in  violation 
of  state  and  federal  law.   The  Federal  Emergency  Management  Agency  (FEMA) 
has  Identified  73  deficiencies  in  the  plans  and  emergency  drills.  MASSPIRG's 
research  reveals  additional  problems  so  serious  as  to  place  the  population 
in  and  near  Plymouth  and  Cape  Cod  at  extreme  risk  if  a  meltdown  occurred. 


166 


-  2 


Hlghllghta  of  MASSFIRC  findings; 

*  Evacuation  planning  only  applies  to  a  lO-mlle  radius  around  Plymouth,  excluding 
Cape  Cod,  even  though  government  studies  estimate  a  serious  meltdown  could  kill 
3,000  people  up  to  20  miles  from  the  reactor. 

*  Only  two-thirds  of  the  permanent  residents  and  no  tourists  have  received 
energency  information,  which  is  lncoiq>lete,  inaccurate  and  contradicts  the 
official  plans  anyway. 

*  There  are  insufficient  warning  sirens  that  are  not  loud  enough,  and  fully 
three-<iuarters  of  the  area  residents  have  heard  false  alarms. 

*  There  are  no  workable  plans  for  evacuating  the  physically  disabled,  nursing 
home  residents,  school  children,  hospital  patients,  campers,  inmates  or  people 
without  cars. 

*  Cape  Cod  will  receive  no  early  warning  of  a  meltdown  and  the  Cape  bridges  Will 
be  closed  to  prevent  Cape  traffic  from  interfering  with  evacuees  from  closer 
to  the  reactor. 

*  Sheltering,  medical  and  evacuation  reception  facilities  are  grossly  inadequate 
to  care  for  the  120,000  summer  residents  and  tourists  (not  counting  the 
summer  Cape  population  of  1/2  million) . 

MASSPIRG  calls  on  the  NRC  to  consider  shutting  down  or  reducing  the  operating 
power  of  Pilgrim  until  emergency  preparedness  is  substantially  upgraded.  MASSPIRG 
also  recommends  that  the  Governor  establish  a  public  emergency  planning  commlssioa 
with  local  representation  to  oversee  the  development  of  workable  emergency  plans. 


167 


EMERGENCY  PLANNING:   AN  OVERVIEW 

"Every  man  for  himself!"  According  to  the  director  of  the  Indian 
Head  Campground,  south  of  Plynouth,  Massachusetts,  that  Is  the  extent 
of  the  evacuation  plan  for  as  many  as  1,000  campers  there  In  case  of  a 
meltdown  at  the  Pilgrim  Nuclear  Power  Plant  just  seven  miles  north. 

Unfortunately,  that  seems  an  apt  characterization  of  the  evacuation  plans 
for  all  the  physically  disabled,  elderly,  nursing  home  residents,  tourists, 
hospital  patients,  and  those  dependent  on  public  transportation  who  are 
in  the  vicinity  of  Pilgrim  Station.   Even  the  Federal  Emergency  Management 
Agency  (FEMA)  acknowledges  there  are  no  fewer  than  73  deficiencies  in  the 

emergency  plana  designed  to  protect  the  public  in  the  event  of  a  Pilgrim 

2 
meltdown.   Taking  into  account  Pilgrim's  safety  record,  the  need  becomes 

urgent  to  develop  and  implement  a  practical  evacuation  plan.  This  study 
is  Intended  as  an  evaluation  of  current  emergency  preparedness  with  recom- 
mendations for  realistic  ways  to  improve  the  current  situation. 

The  Need  for  Emergency  Planning 

Under  certain  reactor  accident  scenarios,  effective  emergency  response 
plans  could  save  thousands  of  lives.   Effective  public  evacuation  or 
sheltering  can  reduce  radiation  exposure  substantially.   For  slow-developing 
reactor  core  meltdowns,  radiation  would  not  escape  into  the  atmosphere  for 
24  hours  or  more,  providing  ample  time  to  evacuate  downwind  areas.   Even 
for  meltdowns  that  develop  more  quickly,  it  is  essential  to  alert  people 


168 


-  2 


Immediately  so  they  can  take  shelter  before  the  radioactive  cloud 
reaches  them.   Like  the  President's  Commission  on  Three  Mile  Island, 
the  Nuclear  Regulatory  Commission's  own  Special  Inquiry  Group,  com- 
*  missioned  to  investigate  that  accident,  concluded  that  "workable  evac- 
uation plans"  should  be  a  "prerequisite  to  continued  operation  of 
existing  and  future  reactors."   Major  Improvements  in  these  plans  were 
recommended  by  both  investigations. 

En^rgency  preparedness  is  crucial  because  even  though  the  likeli- 
hood of  a  meltdown  is  not  great,  the  consequences  of  a  serious  radiation 
release  are  horrendous:   the  government  now  estimates  that  a  "worst-case 
accident"   at  Pilgrim  could  kill  3,000  people  within  a  year,  injure  30,000 

Q 

more,  and  cause  23,000  fatal  cancers.   Total  damages  could  exceed 
$80  billion,  not  including  medical  expenses.   Even  a  minute  chance  of 
such  an  accident  is  cause  for  concern  In  light  of  its  potential  severity. 
The  NRC  discovered  that  the  Three  Mile  Island  reactor  was  "within  30  to  60 

minutes"  of  a  major  core  meltdown  with  "potentially  serious  public  health 

9 
and  safety  consequences."    A  Nuclear  Regulatory  Commission  (NRC)  report 

released  last  summer  evaluated  almost  20,000  "mishaps"  at  nuclear  power 

reactors  from  1969  to  1979  and  concluded  that  accidents  as  serious  as  that 

at  Three  Mile  Island  were  likely  to  occur  once  every  three  to  eight  years 

somewhere  In  the  country.    Directly  after  the  Three  Mile  Island  accident, 

in  fact,  the  President's  Commission  convened  to  study  the  matter  and  made 

about  100  recommendations.   Its  report  concluded  that  even  the  adoption 

of  these  "necessary  fundamental  changes"  could  not  assure  the  safety  of 


169 


-  3 


nuclear  power.    In  fact,  only  a  handful  of  these  "necessary"  changes 
were  ever  adopted  by  the  NRC. 

If  nuclear  power  In  general  Is  cause  for  concern,  the  safety  record 
of  the  Pilgrim  plant  In  particular  Is  positively  alarming.   Of  the  54 

most  serious  "meltdown  precursors"  at  nuclear  plants  nationwide  during 

12 
the  last  decade,  four  occurred  at  Pilgrim.    The  Plymouth  plant  averaged 

one  mishap  a  week  during  1981  and  was  rated  "below  average"  by  the  NK.C 

In  overall  management  and  in  reactor  safety  performance.    Boston  Edison, 

which  owns  and  runs  the  facility,  was  fined  $550,000  in  early  1982  —  the 

largest  fine  ever  collected  from  an  American  nuclear  power  plant  operator  • 

for  disconnecting  a  major  safety  system  for  2^  years  and  then  making  a 

"material  false  statement"  about  it. 


Emergency  Planning  in  Massachusetts 

The  Nuclear  Regulatory  Connisslon's  Special  Inquiry  Group  on  Three 
KLle  Island  discovered  that  the  NRC,  because  of  a  "prevailing  attitude 
that  a  serious  accident  with  releases  beyond  containment  simply  would 
not  happen,"  iiad  not  taken  seriously  its  authority  over  emergency  plan- 
ning. Both  the  Special  Inquiry  Group  and  the  President's  Coimlsslon  on 
Three  Mile  Island  recommended  preparedness  around  nuclear  plants  should 
be  transferred  from  the  NRC  to  the  Federal  Emergency  Hanageiaent  Agency 
(7EMA).    While  retaining  final  authority  over  the  emergency  plans,  NRC 


170 


-  4  - 


did  Issue  new  regulations  in  1980  Chat  require  FEMA  to  review  and 

comment  on  all  state  and  local  plans.    Workable  plans  were  supposed 

18 
to  be  in  place  by  April  1,  1981.    The  regulations  require  FEMA  and 

the  NRC  to  determine  whether  plans  "adequately  protect  the  public  health 

and  safety  by  providing  reasonable  assurance  that  appropriate  protective 

19 

measures  can  and  will  be  taken  in  the  event  of  a  radiological  emergency." 

Tet  even  if  NRC  ultimately  determines  that  a  given  set  of  plans 
are  inadequate,  the  reactor  would  be  permitted  to  continue  operating 
provided  the  utility  could  show  that  any  deficiencies  were  "not  signif- 
icant," that  "compensating  actions  have  been  or  will  be  taken  promptly," 

20 
or  that  "other  compelling  reasons"  exist  to  permit  plant  operation. 

Indeed,  the  NRC  has  already  used  this  escape  clause  to  permit  the  con- 
tinued operation  of  the  Indian  Point  reactors  in  New  York.  Despite  FQ(A 
findings  that  the  emergency  plans  for  Indian  Point  still  contained  sig- 
nificant deficiencies  more  than  two  years  beyond  the  deadline,  the  NRC 

21 
refused  to  take  any  enforcement  action.    NRC  Commissioner  Asselstine 

charged  the  decision  "made  a  mockery"  of  the  NRC's  regulations. 


The  burden  of  drawing  up  emergency  plans  in  the  Commonwealth  falls 
to  the  Massachusetts  Civil  Defense  Agency.   In  the  event  of  a  serious 
accident  at  Pilgrim,  Boston  Edison's  reactor  operators  are  to  notify 
state  police  while  taking  steps  to  prevent  a  radioactive  release.  The 
state  police  in  turn  notify  the  Department  of  Public  Health  (DPH) , 


171 


5  - 


state  and  local  civil  defense  officials  and  local  town  selectmen.  DPH 
has  primary  responsibility  for  determining  the  extent  of  danger  presented 
to  the  public  and  recommending  protective  actions.   Radiation  information 
•Is  obtained  directly  from  the  utility  and  from  independent  evaluation 
teams  in  the  field.   These  "Nuclear  Incident  Advisory  Teams"  from  Boston 
collect  air  samples  downwind  from  the  reactor  and  perform  radiation 
analyses.  On  the  basis  of  this  information,  the  DPH  recommends  a  course 
of  action  to  the  Governor.   Evacuation  may  be  ordered  by  the  Governor,  the 
Commissioner  of  Public  Health,  the  state  director  of  civil  defense,  or  by 
the  local  Board  of  Selectmen.  The  Civil  Defense  Agency  actually  conducts 
the  evacuation.   (The  plan,  of  course,  contains  further  specifications 
regarding  the  notification  of  the  public  and  evacuation  procedures,  and 
it  is  these  details  with  which  the  present  report  is  particularly  concerned.) 

The  attempt  by  Boston  Edison  and  state  civil  defense  to  develop  a 
comprehensive  emergency  response  plan,  however,  was  doomed  from  the  start 
by  the  failure  to  Include  local  communities  in  the  planning  process. 
Only  long-term  residents  have  a  complete  understanding  of  local  resources, 
capabilities,  needs  and  even  likely  evacuation  obstacles.  As  a  result, 
carefully  planned  "emergency"  drills  may  demonstrate  the  ability  of  emer- 
gency officials  to  communicate  with  each  other,  but  they  do  not  indicate 
whether  100,000  local  people  could  be  notified,  mobilized  and  evacuated 
in  case  of  a  real  emergency. 


172 


-  6 


In  1977,  MASSPIRG  published  a  report  evaluating  emergency  plans 
for  nuclear  reactors  In  Massachusetts.   The  report,  entitled  "Nuclear 
Evacuation  Planning:   Blueprint  for  Chaos,"  concluded  that  planning  was 
"shoddy  and  a  reactor  accident  would  place  citizens'  safety  in  Jeopardy," 
Six  years  later,  we  are  forced  to  reach  the  same  conclusion, 

A  careful  review  of  the  current  emergency  plans  reveals  major  prob- 
lems  with  every  section.   In  Septenfcer  of  1982,  FEMA  found  73  deficiencies.^ 
Not  only  do  the  plans  fall  short  of  FEMA's  basic  standards,  but  they  seem 
sloppily  concleved  and  Incapable  of  implementation.   The  result,  we  fear 
could  be  tragedy  on  a  mass  scale.   The  plan  is  analyzed  in  four  chapters, 
as  follows:  first.  The  Emergency  Planning  Zone  size  is  evaluated  to 
determine  whether  the  plan  is  designed  to  protect  all  the  residents  who 
actually  would  be  affected  by  an  accident;  second,  we  examine  the  procedure 
for  informing  residents  in  advance  about  what  to  do  in  case  of  an  accident 
at  Pilgrim;  third,  the  emergency  warning  system,  intended  to  inform  residents 
at  the  time  of  an  accident,  is  evaluated;  and  finally,  we  examine  the  actual, 
evacuation  and  sheltering  plans  and  other  procedures  for  protecting  the 
populace.  Specific  recommendations  for  improving  the  emergency  plan  are 
offered  after  each  section. 


173 


I,   THE  EMERGENCY  PLANNING  ZONE 

The  first  consideration  in  regard  to  planning  for  a  nuclear  power 
plant  accident  is  the  size  of  the  area  involved.   This  is  known  as  the 
Emergency  Planning  Zone  (EPZ) ,  and  it  obviously  should  be  large  enough  to 
Include  virtually  all  people  who  would  likely  be  exposed  to  significant 
doses  of  radiation  in  case  of  a  reactor  malfunction.    In  fact,  though,  current 
plans  limit  the  EPZ  to  areas  within  10  miles  of  Pilgrim.  This  is  a  conse- 
quence of  both  NRC  guidelines  and  a  determination  by  Boston  Edison  and  the  • 
Civil  Defease  Agency.   In  any  case.  It  proves  on  inspection  to  be  absurdly 
Inadequate,  with  the  result  that  thousands  of  people  who  might  suffer  from  a 
nuclear  accident  are  utterly  without  protection  in  the  emergency  plans.    , 

The  NRC  has  decided  Chat  EFZ's  should  be  about  10  miles  in  radius, 
with  site-specific  adjustments  based  on  local  "demography,  topography, 
land  characteristics,  access  routes,  and  jurisdictional  boundaries," 
The  effect  of  these  additional  criteria  is  considered  below,  but  it  should 
first  be  noted  that  even  as  a  rough  guideline,  a  10-mile  EPZ  is  wholly  In- 
adequate. Several  lines  of  analysis  lead  to  this  conclusion: 

*  The  NRC's  own  rationale  is  that  70Z  of  core  meltdowns  would  not 

2 
result  in  harmful  doses  of  radiation  beyond  10  miles  for  a  typical  reactor. 

By  Its  own  estimate,  then,  the  suggested  EPZ  would  be  inadequate  for  nearly 

a  third  of  all  major  accidents.  Of  this  group,  two-chirds  will  result 

in  harmful  doses  out  to  20  miles,  and  the  remainder  to  between  40  and  50 

miles. 


174 


-  8  - 


*  A  recent  govemnent  study  determined  that  a  worst-case  accident 
at  Pilgrim  could  kill  people  as  far  as  20  miles  from  the  reactor  and  cause 
Injuries  65  miles  away.    (Boston  city  limits  are  less  than  35  miles  from 
the  plant.) 

*  If  adequate  EPZ  size  Is  best  judged  under  actual  accident 
conditions,  it  is  useful  to  recall  that  the  NRC  ordered  evacuation  plans 
developed  for  those  living  within  20  miles  of  Three  Mile  Island. 

*  California  took  seriously  the  hazards  presented  by  major  melt- 
downs  and  established  EPZ  boundaries  ranging  from  18  -  35  miles  from  the 

^   6 
reactor . 

The  NRC  10-mile  EPZ  is  based  on  an  outdated  accident  probability  study, 
and  Is  proposed  with  the  suggestion  that  more  serious  accidents  could  be 

Q 

handled  on  an  "ad- hoc  basis."    (Thus,  the  varied  and  complicated  infor- 
mation needed  to  effect  an  evacuation,  much  of  which  is  not  even  available 
for  the  10-mile  EPZ  after  three  years  of  planning,  is  supposed  to  be 
collected  in  a  matter  of  hours.)   Yet  even  the  woeful  inadequacy  of  these 
guidelines  is  somewhat  mitigated  by  the  criteria  offered  for  site-specific 
adjustments,  listed  above.   Unhappily,  all  of  these  criteria  but  one  have 

been  Ignored  in  designating  a  10-mile  EPZ  for  Pilgrim.   Only  the  jurisdic- 

9 
tional  boundaries  of  area  towns  were  considered;   the  high  population 

density  of  the  area,  particularly  during  the  summer,  was  not  a  factor. 

Neither  were  topography,  land  characteristics,  or  access  routes.  People 

outside  the  designated  EPZ  are  very  likely  to  evacuate  even  if  not  required 

to  do  so:   2,500  women  and  young  children  were  ordered  to  leave  the  Three 


175 


-  9 


Mile  Island  area,  but  144,000  actually  left.    Planning  must  account 
for  this  de  facto  evacuation  and  the  question  of  access  routes  becomes 
particularly  critical.   The  only  expressway  in  the  area.  Route  3,  is 
already  jannned  on  summer  weekends,  and  the  only  exits  off  Cape  Cod  are 
two  bridges  less  than  15  miles  from  the  reactor.   Incredibly,  the  Civil 
Defense  Agency  has  decided  that  if  the  wind  is  blowing  south  when  a 
serious  accident  occurs,  the  Cape  bridges  are  to  be  closed.    If  resi- 
dents Just  outside  the  10-mile  EPZ  are  not  included  in  emergency  planning, 
they  will  not  receive  information  on  where  and  how  to  evacuate  or  whether 
to  take  shelter  instead  of  evacuating.   Limiting  the  size  of  the  EPZ 
without  consideration  to  the  certain  evacuation  of  those  outside  it 
therefore  results  in  creating  greater  danger  for  residents  both  inside 
and  outside  of  the  zone. 

Recommendations : 


A  site-specific  analysis  of  accident  probabilities  and  consequences  of 
radioactive  releases  and  of  the  probable  health  effects  at  various 
distances  from  the  plant  should  be  undertaken  promptly.   Civil 
Defense  -should  hire  independent  consultants  for  this  purpose,  with 
Boston  Edison  paying  all  attendant  costs.   The  ultimate  objective  should 
be  to  establish  an  emergency  planning  zone  including  Cape  Cod  that  covere 
all  persons  at  risk  of  receiving  harmful  doses  of  radiation  from  major 
core  meltdowns. ^ 


176 


-  10 


II.   ADVANCE  INTORMATION  TO  THE  PUBLIC 

No  plan  for  a  nuclear  accident  can  hope  to  save  lives  If  residents 
know  nothing  of  its  provisions  until  the  accident  occurs.   Conmon  sense 
dictates  that  the  public  must  be  familiar  with  evacuation  and  sheltering 
procedures  before  a  major  crisis  develops,  as  well  as  the  relative 
benefits  of  these  two  responses.  There  is  evidence  that  many  people  will 
evacuate  before  directed  to  do  so,  and  many  others  will  not  evacuate  even 
when  ordered  to  leave. 

Recognizing  the  importance  of  advance  public  information  for  emer- 
gency preparedness,  FEMA  and  NRC  developed  several  criteria  to  promote 
maxlnua  public  education  on  protective  actions.  Specifically,  the  federal 
ccl^terla  require  provision  of  information  on  nuclear  radiation  hatarda, 
protective  measures  Including  evacuation  routes,  sheltering,  respiratory 

protection,  radioprotective  drugs,  special  needs  of  tourists  and  the  physically 

2 
disabled,  and  where  to  get  additional  Information. 

Adequate  dissemination  of  information  involves  using  several  methods 
rather  than  just  one.  FEMA  and  NRC  recommend  including  emergency  infor- 
mation In  the  phone  book  and  with  utility  bills,  as  well  as  posting  notices 
In  public  areas.   New  York's  public  education  program  includes  public  ser- 
vice announcements  on  the  radio,  newspaper  advertisements,  and  a  speakers' 
program,  while  the  EPZ  for  Verncnt's  Yankee  nuclear  plant  contains  large 
orange  posters.   In  the  Plymouth  area,  by  contrast,  a  pair  of  emergency 
pamphlets  is  the  only  method  for  informing  the  public  about  a  nuclear 


177 


11  - 


emergency.   Beyond  the  general  Inadequacy  of  this  situation,  some 

451000  tourists  who  are  in  the  area  each  summer  weekend  and  24,000 

4 
seasonal  residents  are  utterly  without  Information.   FEMA  considers  this 

glaring  omission  a  "significant  deficiency."    The  Chamber  of  Commerce 

has  opposed  any  efforts  to  educate  the  tourists  for  fear  of  scaring 

them  away. 

Even  if  the  two  pamphlets,  prepared  by  the  DPH  and  Civil  Defense 

Agency,  were  universally  distributed  and  exemplary,  they  would  be 

insufficient  to  educate  the  public.   In  fact,  though,  they  are  neither. 

The  two  publications  —  "Emergency  Public  Information,"  with  evacuation 

and  sheltering  instructions,  and  "Nuclear  Energy  —  Questions  and 

Answers,"  with  more  general  Information  on  radiation  —  were  supposedly 

mailed  to  all  households  in  the  EPA  in  the  fall  of  1982.   MASSPIRG's 

telephone  survey  of  100  area  residents,  however,  discovered  that  only 

2/3  of  the  respondents  had  ever  received  the  pamphlets  and  Just  1/6 

still  had  them  available.    Emergency  authorities  have  made  no  effort 

to  ascertain  how  many  pamphlets  were  received  or  how  little  their  contents 

were  understood.   Only  9X  of  the  respondents  knew  they  should  tune  in 

their  radio  or  TV  to  an  Emergency  Broadcast  system  station  when  they 

g 
heard  the  Pilgrim  warning  siren. 

As  regards  the  contents  of  the  brochures,  serious  deficiencies 

exist: 

(1)      The  educational   information  on  radiation  in   the   "Nuclear 

Energy"  pamphlet  does  not  convey   the  real  danger  of   serious  meltdowns. 


178 


179 


-  12 


The  probability  estlnaces  of  melcdowns  from  the  outdated  1975  Reactor 

9 
Safety  Study  are  called  the  "best  available."    The  pamphlet  also 

understates  the  hazards  of  radiation  releases  from  reactors.  The  effect 

is  to  reinforce  the  inclination  of  many  people  to  ignore  evacuation 

orders.  Less  than  1/3  of  the  survey  respondents  realized  that  radiation 

released  from  a  major  meltdown  could  cause  death.    If  ordered  to  evacuate, 

7Z  (nearly  4,000  people)  would  not  leave. 


(2)  The  Plymouth  Town  Plan  stipulates  that  "most  residents  of 
nursing  homes  will  be  evacuated  by  private  automobile."  but  the 

"Emergency"  Pamphlet  specifically  warns  that  people  should  not  pick  up 

12 
nursing  home  residents  because  transportation  will  be  provided  for  them. 

(3)  While  the  Plymouth  Town  Plan  Includes  13  "staging  areas" 

where  "persons  without  transportation  will  be  directed  for  possible  public 

13 
transport,"  the  Emergency  Pamphlet  makes  no  mention  of  their  existence 

or  locations. 

(4)  Sheltering  instructions  (found  only  in  the  Nuclear  Energy 
Pamphlet)  provide  no  directions  to  public  shelters  for  tourists  or 
residents  without  basements.   There  are  no  Instructions  on  ad  hoc 
respiratory  protection  from  contaminated  air. 

(5)  Regarding  evacuation  of  the  physically  disabled,  the  pamphlet 
siiqtly  states:   "The  disabled  and  those  requiring  special  assistance 


180 


13  - 


^hould  concact  the  (local  civil  defense)  offices  listed  belov  so  that 
adequate  preparation  can  be  made  and  assistance  provided.   Do  not  call 
during  an  emergency  unless  absolutely  necessary. "  There  is  no  elabor- 
ation on  evacuation  procedures  for  the  disabled.   The  MASSPIRG  survey 

revealed  that  n£  one  had  called  the  Plymouth  Civil  Defense  to  arrange 

14 
for  evacuation  assistance  yet.    That  means  when  an  accident  happens, 

everyone  needing  transportation  assistance  will  be  trying  to  call  the 

civil  defense  office  at  the  same  time  everyone  else  in  town  is  trying 

to  call  there  to  find  out  what's  going  on.  With  everyone  calling  the 

office,  very  few  will  get  through  (phone  lines  to  the  police  are  already 

tied  up  whenever  the  sirens  go  off  accidentally   ). 


(6)   Four  of  the  five  telephone  numbers  listed  for  "local  civil 
defense  offices"  do  not  reach  these  offices  and  none  reach  the  local 
civil  defense  director.    The  phone  nunijer  listed  for  Carver  Civil 
Defense  is  the  number  for  reporting  burglaries  at  the  police  station,  and 
the  first  forwarding  number  provided  for  the  civil  defense  director  turned 

out  to  be  a  wrong  number!     The  failure  to  update  phone  numbers  in  the 

18 
plan  quarterly  was  considered  a  "significant  deficiency"  by  FEMA. 


(7)   The  state  plan  directs  that  "the  special  needs  of  persons 

19 
within  the  EPZ  who  are  ...  non-English  speaking"  will  be  addressed. 


181 


This  is  especially  important  in  North  Plymouth  and  other  neighborhoods 
In  the  areas  vhich  contain  large  Italian  and  Portugese  communities.   The 
Emergency  pamphlet,  however.  Is  published  only  in  English. 


Recommendations : 


1)  The  Nuclear  Energy  Pamphlet  should  be  updated  with  the  latest  federal 
estimates  of  the  probability  and  consequences  of  serious  laeltdowns  to 
Impress  upon  the  public  the  importance  of  following  official  instructiona 
during  an  emerge.icy. 

2)  The  State  and  Town  Plans  and  the  Emergency  Pamphlet  must  be  updated  to 
provide  realistic  and  consistent  emergency  response  plans. 

3)  The  location  of  "staging  areas"  for  public  transportation  must  be 
included  on  maps  in  all  emergency  information  materials. 

4)  The  location  of  public  shelters  must  be  Included  on  maps  in  all 
emergency  information  materials. 

5)  A  confidential  list  of  all  physically  disabled  persons  in  the  EPZ 
should  be  compiled  by  civil  defense  officials,  and  practical  plana  for 
their  evacuation  should  be  developed.   Practical  plans  for  evacuating 

the  physically  disabled,  school  children,  nursing  home  residents,  hospital 
patients,  canqjers,  institutionalized  persons  and  people  without  24-hour 
access  to  cars  should  all  be  clearly  spelled  out  in  all  emargency  information 
materials. 

6)  The  correct  telephone  numbers  for  the  local  civil  defense  offices  or 
directors  should  be  Included  in  all  emergency  information  materials. 

7)  A  comprehensive  public  education  program  including  radio  and  TV 

public  service  announcements  and  a  speakerNLs  bureau  to  educate  all  residents 
of  the  EPZ  should  be  implemented  to  supplement  the  pamphlet.   This  program 
should  include  an  evaluation  component  to  confirm  that  the  public  is 
being  adequately  informed, 

8)  A  program  must  be  developed  for  providing  emergency  information 

to  tourists  through  distribution  of  Emergency  Pamphlets,  large  posters, 
and  telephone  book  inserts  to  all  "hotels,  motels,  gasoline  stations," 
restaurants  and  other  public  facilities  in  the  EPZ. 

9)  Emergency  information  materials  should  be  distributed  in  Portuguese, 
Italian  and  Japanese. 


182 


16 


HI.  NOTIFICATION  DURING  AN  ACCIDENT 

Assuming  all  the  people  In  the  EPZ  were  pro\d.ded  with  sufficient 
Information  so  that  they  were  prepared  to  react  properly  in  an  emergency, 
it  would  still  be  necessary  to  provide  immediate  and  comprehensive  no- 
tification as  soon  as  trouble  was  detected.   Federal  authorities  estimate 
that  a  nuclear  accident  could  release  substantial  amounts  of  radioactivity 
as  early  as  30  minutes  after  the  "initiating"  event.    Once  again, 
people  living  in  the  vicinity  of  the  Pilgrim  plant  are  endangered  due 
to  Inadequate  planning. 

Notifying  Authorities 

Under  current  plans,  the  scheduled  chain  of  emergency  responses  is 
begun  by  Boston  Edison's  reactor  operators.  The  very  organization  with 
the  greatest  investment  in  convincing  people  that  nuclear  power  is  safe, 
in  other  words,  has  the  discretion  to  decide  when  (or  whether)  to  tell 
the  state  police  that  something  has  gone  wrong.   An  incentive  exists  for 
Edison's  reactor  operators  to  delay  reporting  until  they  can  correct  the 
malfunction  and  then  report  that  everything  is  under  control.   Indeed, 
within  the  past  year  alone,  the  NRC  discovered  three  notification  viola- 
tions for  Boston  Edison's  failure  to  provide  prompt  notification  of 
problems  which  developed  during  reactor  deration.   While  two  NRC 


183 


-  17  - 


Inspectors  are  assigned  to  oversee  operations  at  Pilgrim,  they  are 
on  duty  for  only  about  half  of  the  operating  hours. 

,  Notifying  the  Public:   Sirens 

The  NRC  now  requires  a  system  capable  of  notifying  the  public  In  the 

3 
EPZ  vrlthin  15  minutes  —  a  requirement  curiously  Interpreted  by  FEMA 

to  refer  only  to  people  living  within  five  miles  of  the  site,  with  those 
In  the  rest  of  the  EPZ  to  be  notified  within  45  minutes.    In  fact,  the 
current  siren  warning  system  in  and  around  Plymouth  meets  neither  of 
these  specifications.   This  is  demonstrated,  first,  by  admissions  from 
the  system's  designers,  and  second,  by  results  from  a  siren  test. 

Stone  &  Webster  Engineering  Corporation  designed  the  fixed  siren 
alert  system  to  reach  about  902  of  EPZ  residents  and  98%   of  those  living 
within  five  miles.   The  conqjany  recommended  installation  of  250  tone- 
activated  Emergency  Broadcast  System  (EBS)  alarms  to  make  sure  the  remain- 
ing people  within  five  miles  were  notified  and  to  provide  back-up  notifi- 
cation for  "schools,  hospitals,  nursing  homes,  police  and  fire  departments, 
and  possibly  for  some  hotel/motel  offices."   Even  if  these  EBS  receivers 
were  provided  —  and  they  have  not  been  —  the  engineering  firm  admits  that 
some  people  living  between  five  and  ten  miles  from  the  reactor  would  not 
hear  a  siren.    In  effect,  the  very  design  of  the  siren  system  now  in  use 
fails  to  meet  federal  requirements. 


184 


-  18  - 


On  June  19,  1982,  the  whole  siren  system  was  tested.  Almost  half 
(473!)  of  the  FIMA  observers  reported  the  sirens  were  "inaudible"  or  "barely 
audible."    The  sirens  "did  not  generally  wake  people  that  were  asleep," 
and  between  seven  and  nine  of  the  90  sirens  did  not  work  at  all.   Noting, 
moreover,  that  the  test  was  conducted  on  a  warm  summer  day,  the  observers 
determined  there  was  a  "strong  possibility  that  a  significant  portion  of 
households  within  the  EPZ  would  not  be  alerted  by  the  fixed  siren  signal 

Q 

under  adverse  conditions"  with  windows  and  doors  closed.   Their  suspicions 

were  confirmed  by  nearly  half  of  the  MASSFIRG  survey  respondents  for  both 

9 
offices  and  homes.   FEMA  concluded  that  "fixed  sirens  alone  will  not  Insure 

the  necessary  coverage."     After  a  similar  evaluation  at  Indian  Point, 

the  utilities  there  agreed  to  Install  an  additional  17  sirens. 

In  addition,  the  observers  reported  several  unsolicited  complaints 

12 
from  residents  that  the  sirens  were  often  activating  accidentally.    The 

MASSFIRG  survey  found  that  77Z  of  respondents  had  heard  unplanned  sirens. 

Two-thirds  of  these  people  had  heard  at  least  three  and  ISZ  heard  more  than 

7  false  alarms!    FEMA  stated  that  accidental  activation  of  sirens  reduces 

their  credibility,  "causing  some  residents  to  disregard  the  alerting  signal." 

This  assertion  was  also  corroborated  by  the  MASSFIRG  survey:   19Z  of 


respondents  said  if  they  heard  the  siren  again,  they  would  assume  It  was 
accidentally  activated  and  Ignore  it.    We  also  were  asked  the  following 
question:  "Why  can't  they  Improve  the  sirens  so  people  would  believe  them7" 


185 


"Why  can't  they  Improve  the  sirens  so  people  would  believe  them?"  ^^ 

To  determine  whether  a  siren  was  a  false  alarm,  nearly  one-third 
of  those  surveyed  said  they  would  telephone  someone  —  usually  the 
poll,ce  or  fire  department.   The  fact  that  no  one  will  be  able  to  get 
a  call  through  has  already  been  demonstrated.   The  superintendent  of 
the  state  prison  in  Plymouth  con^ilained  that  even  he  could  never  find 
out  what  was  going  on.   "The  sirens  are  always  going  off.  The  inmates 
and  staff  panic  and  I  don't  know  what  to  do  -  so  I  call  the  police  but 
1  can  never  get  through." 

Finally,  back-up  vehicles  with  loudspeakers  are  supposed  to  go 
out  and  alert  all  areas  where  the  sirens  don't  work.  Unfortunately,  there 
is  no  plan  for  discovering  which  sirens  don't  work. 

Overall.  FEMA  concluded  the  siren  system  did  not  meet  "minimum 
federal  standards."  ^^ 


Notifying  the  Public;   EBS 

Federal  guidelines  also  call  for  civil  defense  officials  to  notify 
Emergency  Broadcast  System  (EBS)  stations  in  the  evBnt  of  a  serious 
accident. '5  Anyone  watching  television  or  listening  to  the  radio  would 
be  instructed  to  turn  to  an  EBS  station  which,  in  turn,  would  provide 
emergency  instructions.   On  June  3,  1982.  an  accident  occurred  that  was 
claasified  as  serious  enough  to  warrant  notification  of  EBS  stations,  but 
this  did  not  happen. 


186 


20 


Rumors  about  the  severity  of  the  accident  spread  as  a  result,  and  many 

20 
citizens  were  understandably  upset.    Even  during  the  official 

emergency  drill  last  year,  officials  failed  to  notify  one  of  the  EBS 

21 
stations. 


Notifying  the  Deaf 

According  to  the  Massachusetts  Office  of  the  Deaf,  39,000  people 
in  the  CommDnwealth  are  totally  deaf  and  another  335,000  have  serious 
hearing  deficiencies.   Of  the  80,000  residents  in  the  Pilgrim  EPZ, 
there  are  probably  at  least  one  hundred  deaf  people  and  another  thousand 

who  would  be  unable  to  hear  the  warning  sirens,  let  alone  radio  announce- 

22 
ments  or  telephone  warnings. 

Federal  regulations  require  notification  of  "all  segments"  of  the 

23 
population,    and  the  state  plan  directs  that  "TV  overprinting  will  be 

provided  for  hearing-impaired  persons  on  area  EBS  television  broadcasts 

during  an  emergency."     But  what  of  those  people  in  the  target  group 

who  do  not  happen  to  be  watching  television  when  an  accident  occurs? 

Local  officials  are  to  maintain  "confidential  listings  of  households  and 

25 
individuals  requiring  assistance  due  to  special  needs.'     No  such  lists 

have  been  compiled,  and  no  plan  exists  to  notify  the  hearing-impaired 

promptly  in  case  of  emergency. 


187 


-  21 


Reconmendaclons : 


1)  TniC  Inspectors  should  be  on  duty  In  the  reactor  control  room 

24  hours  a  day  to  insure  the  Imniediate  notification  of  emergency  officials 
whenever  problems  develop. 

2)  Enough  sirens  should  be  Installed  so  that  tests  confirm  lOOZ  coverage 
of  Che  EPZ  with  windows  closed. 

3)  Alarms  should  be  installed  in  every  non-residential  building  in  the 
EPZ,  with  a  procedure  developed  to  confirm  that  the  sirens  are  in 
working  order. 

4)  A  system  for  determining  promptly  whether  every  siren  is  functioning 
oust  be  iiq)leaented. 

5)  Civil  defense  officials  should  determine  the  number  of  vehicles  with 
loudspeakers  necessary  to  alert  residents  of  any  area  within  45  minutes  in 
case  a  siren  fails. 

6)  Boston  Wison  should  provide  a  teletypewriter  for  every  deaf  person 
in  the  EPZ.^° 

7)  Capability  for  TV  overprinting  for  hearing  impaired  tourists  and 
seasonal  residents  must  be  available  on  a  24-hour  basis. 


188 


22  - 


IV.   FVACUATION  PLANS,  SHELTERING,  AND  OTHER  PREPARATIONS 
The  Decision  to  Evacuate 

In  the  event  of  an  appreciable  release  of  radiation,  officials  must 
decide  promptly  whether  to  order  evacuation  or  sheltering  of  the  public 
downwind  from  the  reactor.   Evacuation  Is  the  preferred  protective  action 
because  it  prevents  any  radioactive  exposure.   Since  cars  provide  very 
little  shielding  against  radiation,  however,  sheltering  in  basements  or 
large  buildings  provides  greater  protection  from  radiation  exposure  if 
there  were  insufficient  time  to  evacuate  before  the  radioactive  cloud 
passed  through  the  area. 

If  an  order  to  evacuate  is  given  with  insufficient  time  to  clear  the 
area,  thousands  of  people  could  be  trapped  in  bumper-to-bumper  traffic 
and  irradiated  as  they  are  overtaken  by  the  radioactive  cloud.   Before 
ordering  an  evacuation,  emergency  officials  must  be  reasonably  confident 
that  the  time  necessary  to  evacuate  an  area  is  shorter  than  the  time  it 
will  take  for  the  radiation  to  escape  from  the  reactor  and  blow  through 
chat  same  area. 

The  decision  to  order  evacuation  or  sheltering,  therefore,  depends 
on  three  key  estimates:   the  timing  of  a  release  of  radioactivity  from  the 
reactor,  the  direction  and  velocity  of  the  radioactive  cloud  after  release, 
and  the  amount  of  time  required  to  evacuate  the  area.    Unfortunately, 
the  weather  bureau's  prediction  of  wind  velocity  and  direction 


189 


23 


over  the  next  several  hours  is  likely  to  be  more  reliable  than  the 

other  tvro  estimates.   Emergency  officials  must  rely  on  Boston  Edison's 

reactor  operators  to  give  an  accurate  estimate  of  the  time  of  release. 

Hajor  accidents  can  result  in  releases  of  radioactivity  into  the  air  as 

early  as  half  an  hour  or  as  late  as  a  day  or  more  after  the  accident 

2 
begins.   Depending  on  the  particular  accident  scenario,  guessing  when 

a  significant  release  of  radiation  may  occur  could  be  a  very  speculative 

task. 

The  estimates  of  the  amount  of  time  necessary  to  evacuate  downwind 
areas,  while  also  speculative,  are  the  only  estimates  that  can  be.  pre- 
dicted even  roughly  in  advance  of  an  accident.   Boston  Edison  hired 
transportation  consultants,  HMM  Associates,  to  develop  evacuation  tine 
estimates  through  the  use  of  a  sophisticated  computer  code.   Their  results, 
however,  are  based  on  completely  unrealistic  assumptions  and  seriously 
underestimate  the  time  that  would  actually  be  required  to  evacuate  each 
sector. 

More  specifically,  they  ignored  the  fact  that  obstacles  to  heavy 
traffic  flow  outside  the  evacuation  zones  will  Impair  prompt  evacuation 
Inside  the  areas  ordered  to  evacuate,  that  many  people  outside  designated 
evacuation  zones  will  also  evacuate,  that  some  drivers  will  panic  and 
create  traffic  disorder,  that  thousands  of  residents  do  not  have  24-hour  access 
to  a  car  and  will  need  public  transportation,  and  that  different  types  of 
adverse  weather  and  evacuating  at  different  times  of  the  day  and  the  week 
will  also  affect  the  time  necessary  to  evacuate  various  areas. 


190 


24  - 


HMM  Associates  estimated  It  would  take  160  minutes  to  evacuate  the 

10-mile  sector  south  of  Pilgrim  Station.   NRC  consultants  conducted  a 

3 
separate  analysis  and  produced  an  estimate  of  410  minutes.   HMM  Associates 

then  updated  its  study  to  include  a  "critical  bottleneck"  in  traffic  at 

the  Sagamore  rotary,  Just  one  mile  outside  the  EPZ,  and  concluded  the 

4 
correct  time  was  315  minutes.   A  discrepancy  of  over  an  hour  and  a  half 

still  remains.   One  wonders  how  many  other  traffic  factors  —  jams  on 
Routes  6  and  25,  for  example  —  were  not  considered  in  one  or  both 
analyses. 

HMM  Associates  also  stubbornly  refuses  to  acknowledge  that  people 
living  outside  the  designated  evacuation  sectors  are  likely  to  leave.   As 
noted  earlier,  144,000  people  evacuated  from  around  Three  Mile  Island  even 
though  only  2,500  people  were  ordered  to  do  so.   This  single  piece  of 
evidence  is  so  compelling  as  to  demand  that  evacuation  estimates  be  re- 
considered immediately.   As  one  study  put  it: 

In  planning  for  an  evacuation  from  a  nuclear 
disaster,  it  can  therefore  be  projected  that 
any  order  to  evacuate  will  cause  the  departure 
of  residents  not  only  from  a  designated  zone 
but  also  from  its  peripheries. 

The  attendant  traffic  Jams  from  this  phenomenon  would  likely  be  so  enor- 
mous that  untold  thousands  would  be  in  extreme  danger,  and  this  situation 
is  exacerbated  by  the  failure  to  educate  those  outside  the  EPZ  about 
evacuation  routes  or  procedures. 


191 


o 
•o 


0) 

E 
o 


■a 


4-1 

o 


■a 


u 

V 

u 
v 


> 

u 


41 


192 


25 


Furthermore,  neither  the  estimates  by  HMM  Associates  nor  by  the 
NRC  allow  for  the  possibility  of  panic  and  traffic  disorder.   Substan- 
tiating  this  commonsense  concern  was  a  1980  report  by  transportation 
consultants  for  FEMA:   "Experiences  such  as  major  snowfalls  (even  in 
regions  accustomed  to  such  types  of  weather)  suggest  that  driver  behavior 
deteriorates  quite  regularly  under  circumstances  of  30-  to  90-minute 
delays."    One  could  expect  such  behavior  as  blocking  cross  streets, 
disregarding  traffic  signals,  driving  in  the  left-hand  lane  against 
traffic,  abandoning  vehicles,  and  many  accidents  as  a  result,  according 
to  the  study.   In  fact,  it  predicted  a  50%  reduction  in  traffic  flow 
compared  to  disciplined  traffic.   With  ineffective  traffic  control, 
evacuation  estimates  concerning  the  Seabrook  plant  should  be  doubled. 
Yet  those  people  preparing  estimates  on  the  time  necessary  to  evacuate 
the  Plyncuth  area  —  the  estimates  that  will  form  the  basis  of  a  llfe- 
and-death  decision  —  assume  that  normal  traffic  conditions  will  prevail. 

Moreover,  the  estimates  by  HMM  Associates  fail  to  consider  the  time 
necessary  to  evacuate  the  nursing  homes,  schools,  hospitals,  campgrounds, 
physically  disabled  and  people  without  24-hour  access  to  cars.   In  fact, 

g 

MBTA  buses  will  be  called  in  from  Boston.    No  estimates  have  been  developed 
for  the  time  required  to  bring  in  sufficient  buses  at  different  tines  of 
the  day,  week,  and  year  and  under  various  weather  conditions.   Indeed, 
federal  guidelines  require  not  just  one  evacuation  time  estimate,  but  a 

variety  of  estimates  for  different  times  of  the  day  and  different  weather 

9 
conditions  for  each  sector  around  the  reactor.    Boston  Edison's  only 


193 


-  26 


time  estimates  are  for  peak  and  typical  population  during  normal  and 

10 
adverse  weather,  falling  far  short  of  the  multiple  federal  requirements. 

Because  of  these  various  deficiencies  —  failure  to  account  for  panic, 

traffic  disorder,  public  transportation  -  dependent  Individuals,  and 

so  forth  —  the  Mass.  Attorney  General  also  has  concluded  that  the 

U 
evacuation  time  estimates  are  Inaccurate. 

Even  if  HUM  Associates  considers  these  new  factors,  the  new  time 

estimates  will  remain  speculative.   Given  all  the  uncertainties  involved, 

the  decision  to  order  evacuation  should  only  be  made  when  the  best 

estimate  for  a  radiation  release  exceeds  the  new  evacuation  time  estimates 

by  a  substantial  margin. 

Recommendations: 


1.  Given  the  difficulty  in  predicting  the  time  when  radioactivity  may  be 
released  from  a  meltdown,  reactor  operators  and  NRC  Inspectors  should  be 
trained  to  make  accurate  estimates  under  various  accident  scenarios.   In 
the  event  of  an  actual  meltdown,  reactor  operators  and  NRC  inspectors  should 
give  emergency  officials  their  best  estimates  together  with  an  indication 
of  the  level  of  confidence  they  have  in  these  estimates. 

2.  Boston  Edison  should  pay  for  a  new  evacuation  time  study  supervised  by 
FEMA.   The  new  study  should  assume  that  a  substantial  amount  of  spontaneous 
evacuation  will  occur  around  the  periphery  of  designated  evacuation  zones, 
that  traffic  obstacles  outside  the  EPZ  such  as  the  Sagamore  rotary  will 
affect  the  amount  of  time  required  to  evacuate  the  EPZ,  that  some  drivers 
will  panic  and  cause  traffic  disorder  and  delays,  and  that  a  substantial 
segment  of  the  population  will  require  public  transportation  to  evacuate. 
The  new  study  must  also  include  separate  evacuation  time  estimates  for 
various  special  population  groups,  for  different  adverse  weather  conditions 
and  for  various  times  of  the  day,  week,  and  year. 


194 


195 


27- 


Speclal  Population  Groups 

While  all  residents  are  at  risk  as  a  result  of  Irresponsible  and 

* 

inadequate  evacuation  time  estimates,  certain  individuals  are  at  an 
even  greater  disadvantage  in  case  of  emergency.   The  plans  fall  to  address 
the  needs  of  specific  populations,  including  handicapped  persons,  nursing 
home  residents,  school  children,  hospital  patients,  and  inmates  as  well  as 
everyone  dependent  on  public  transportation. 

Civil  defense  authorities  have  made  the  assumption  that  private 

automobiles  can  provide  virtually  all  of  the  transportation  required  to 

12 
evacuate  the  population.    In  fact,  this  is  false:  about  13Z  of  Plynouth 

13 
households,  representing  over  4,000  residents,  do  not  own  a  car.    Also, 

14 
nearly  half  of  Plymouth's  workers  have  jobs  outside  the  town.    Should 

an  accident  occur  during  a  weekday,  the  plans  state  that  these  workers 

may  not  be  permitted  to  return  home  to  pick  up  their  families.    Another 

10,000  residents  may  therefore  require  transportation. 

Current  plans  call  for  sending  in  MBTA  and  other  area  buses  to  pick 

up  residents  without  access  to  automobiles.    There  is  no  evidence  that  the 

MBTA  or  any  private  bus  lines  have  ever  been  contacted  about  evacuation 

assistance.   Beyond  the  fact  that  no  written  agreement  exists  to  provide 

for  this  (as  federal  criteria  require   ),  it  would  take  about  350  buses  to 

18 
evacuate  14,000  people    —  and  no  one  has  any  idea  how  long  this  would 

take  or  whether  that  many  buses  could  be  made  available  quickly.   Relying 

on  large  fleets  of  local  buses  raises  another  problem:   most  bus  drivers 

would  evacuate  their  own  families  from  danger  zones  before  reporting  to  drive 


196 


-  28 


an  evacuation  bus.   Two  surveys  of  bus  drivers  in  New  York  confirm  this 

conclusion,  and  the  state  of  New  York  is  connnitted  to  funding  a  "compre- 

19 
henslve  study"  of  the  mass  transit  evacuation  problems.    Finally,  the 

"staging  areas"  where  people  would  be  picked  up  by  buses  are  not  listed 
in  the  emergency  information  pamphlet. 

While  federal  regulations  require  the  development  of  plans  for  "pro- 
tecting those  persons  whose  mobility  may  be  impaired,"  these  persons, 

20 
perhaps  1000,  have  not  even  been  Identified  yet.    Although  the  Massachusetts 

Radiological  Emergency  Response  Plan  states  that  lists  of  the  physically 

21 
disabled  and  elderly  will  be  maintained  by  civil  defense  officials,   the 

PlymDuth  Plan  says  this: 

Because  it  is  not  feasible  to  maintain 
current  lists  of  handicapped  individuals 
within  the  towns,  an  inventory  of  local 
transportation  resources,  both  private  and 
public,  that  would  be  called  upon  to  assist 
any  individuals  having  special  needs  due  to 
handicaps  or  disabilities  will  be  maintained 
by  the  Director  of  Civil  Defense.   In  addition, 
local  agencies  that  serve  the  handicapped 

will  be  called  upon  to  assist  in  the  event  of 

22 
an  emergency. ^^ 

Even  If  this  alternative  were  accepted  as  satisfactory.  It  proves  utterly 

unrealistic  in  practice.   The  "local  agencies"  are  not  specified,  to  begin 

with.   As  for  transportation  resources,  the  MASSPIRG  survey  revealed  that 

only  one  of  the  twelve  ambulance  and  wheel  chair  transit  companies  listed 

in  the  plan  has  been  contacted  regarding  participation  in  an  evacuation  effort. 

Only  one  company  listed  is  within  20  miles  of  Plymouth,  and  it  closed  two 

years  ago.   Five  of  the  six  ambulance  companies  have  no  plans  to  assist 


197 


-  29  - 


and  are  not  prepared  to  handle  radiation  victims.   Gilbert  Gamett, 

owner  of  Bristol  County  Ambulance,  said  he  would  not  send  any  ambulances 

In  the  event  of  a  serious  accident: 

"If  they  want  ambulances,  they'll  have  to  come  get 
them.   No  one  on  my  staff  will  go  anywhere  near  Plymouth 
if  there  is  an  accident  at  the  nuclear  plant."  23 

Of  the  three  wheel  chair  transit  companies  listed  in  the  State  Plan, 

one  Is  a  duplicate  listing  and  the  second  is  for  a  company  that  has  been 

24 
out  of  business  for  four  years.    FEMA's  recent  evaluation  concluded  that 

"no  information  is  found  (in  the  plans)  that  provides  protection  for  the 

mobility  impaired,"  calling  this  a  "significant  deficiency"  in  the  plans. 

Only  one  director  of  all  the  nursing  homes,  campgrounds,  and  correctional 

facilities  listed  in  the  plans  has  ever  been  contacted  about  evacuation  plans, 

and  contradictory  plans  for  evacuating  hospitals  and  schools  add  to  the 

confusion.  Consider: 

*  There  are  five  nursing  homes  in  the  Plymouth  area  alone  which 

27 
the  Plymouth  Plan  states  have  a  total  capacity  of  380  residents.    The 

28 
Plymouth  Plan  calls  for  an  evacuation  of  these  residents  by  automobile, 

but  the  EPZ  brochure  tells  people  not  to  pick  up  nursing  home  residents 

29 
because  transportation  will  be  provided.    A  MASSPIRG  survey  found  that 

the  actual  capacity  of  these  homes  is  about  430,  that  none  had  been  contacted 

about  a  radiological  emergency  (one  spokesperson  assuming  they  would  have 

to  "call  in  the  National  Guard"),  and  that  it  was  not  clear  whether  the  staff 

was  to  evacuate  with  residents. 

*  Flans  call  for  80  to  85  school  buses  to  evacuate  students 


26 


198 


31  - 


When  pressed  to  explain  how  all  these  different  groups  of  people  can 
be  evacuated,  a  civil  defense  official  simply  replied,  "The  Governor  will 
.declare  a  state  of  emergency  and  we'll  order  buses  in  here."     But  how 
many  buses  are  needed?  From  where?  How  long  will  it  take  for  the  drivers 
to  report  and  drive  them  to  the  EPZ7  Where  will  they  go  when  they  get 
there?  These  are  life  and  death  questions  that  cannot  wait  to  be  answered 
correctly  during  the  panic  of  a  real  crisis.   They  must  be  answered  now  so 
that  all  the  kinks  can  be  straightened  out  before  a  meltdown.  Without 
these  answers  an  informed  order  to  evacuate  cannot  be  made. 


Reconmiendatlons : 


1)  A  diligent  effort  must  be  made  to  Identify  all  persons  within  the  EPZ 
who  may  need  transportation  assistance  in  an  evacuation  due  to  physical 
disability. 

2)  Practical  plans  must  be  developed  to  provide  prompt  transportation  for 
each  individual  needing  assistance  to  evacuate. 

3)  Civil  defense  officials  should  meet  with  the  administrators  of  all 
nursing  homes,  medical  facilities,  campgrounds  and  correctional  facilities 
to  develop  workable  evacuation  plans  for  the  residents  and  the  staff  and  to 
Identify  specific  transportation  needs  for  each  institution  at  various  times 
of  the  day,  week  and  year. 

4)  Civil  defense  officials  should  sit  down  with  school  administrators  and 
the  P.T.A.  to  develop  workable  student  and  teacher  evacuation  plans  and 
establish  criteria  for  determining  when,  if  ever,  it  would  be  appropriate 
to  send  children  home  first  to  evacuate  with  their  families. 

5)  Civil  Defense  should  undertake  a  comprehensive  study,  financed  by 
Boston  Edison,  of  public  transportation  resources  available  at  various 
times  of  the  day,  week  and  year.   Written  agreements  should  be  reached  with 
both  transport  companies  and  their  bus  drivers. 


199 


33  - 


Reception  Facilities 

If  any  evacuation  is  ordered,  TV  and  radio  EBS  broadcasts  and  the 
police  will  direct  evacuees  to  designated  "reception  centers"  outside  the 
EPZ.  Evacuees  will  be  monitored  for  radiation  and  decontaminated  (if 

necessary),  re-united  with  family  members,  and  assigned  shelter  and/or 

43 
transportation.    There  are  numerous  problems  with  the  feasibility  and 

safety  of  the  proposed  reception  procedure. 

The  first  and  most  glaring  problem  is  the  location  of  the  reception 

centers.  Two  of  the  three  centers  are  in  exactly  the  same  direction  as 

44 
the  areas  from  which  evacuees  would  be  fleeing!    If  the  wind  were  blowing 

northward  during  an  accident,  evacuees  north  of  Pilgrim  would  be  sent 

north  to  Hanover  Mall,  just  20  miles  downwind  from  Pilgrim.   Government 

figures,  remember,  estimate  a  "worst-case"  accident  could  cause  deaths 

20  miles  downwind  from  the  plant.   Bridgewater  State  College  has  the  same 

problem  since  it  is  located  20  miles  due  west  of  Pilgrim.  Taunton  State 

Hospital,  the  reception  center  for  southern  evacuees  would  also  be  within 

the  radioactive  plume  if  the  wind  were  blowing  southwest.   If  is  unlikely 

in  any  case  that  most  evacuees  would  stop  just  20  miles  downwind  of  a 

nuclear  meltdown. 

A  summer  evacuation  would  send  roughly  40,000  people  to  any  of  these 

45 
reception  areas.    No  one  could  seriously  contend  that  any  of  these  recep- 


tion centers  could  handle  that  many  people  within  the  federal  guideline  of 

46 
12  hours.    During  the  March  3,  1982  drill,  FEMA  reported  that  Hanover 

officials  "questioned  whether  water  and  sewage  facilities  were  adequate  for 


200 


-  34 


47 
potentially  large  numbers  of  people."     Hanover  Mall  does  not  even 

have  adequate  facilities  for  a  few  thousand  people,  let  alone  40,000, 

The  State  Plans  provide  for  decontamination  of  evacuees  and  their 

48 
vehicles.    Several  decontamination  washing  solutions  are  recommended 

for  a  range  of  body  and  vehicle  surfaces  and  degrees  of  contamination. 

The  plans  caution  that  decontamination  wash  "drainage  must  be  controlled." 

Current  reception  centers  do  not  stock  the  recommended  wash  solutions, 

nor  is  there  provision  for  control  of  contaminated  drainage.   FEMA 

criticized  the  lack  of  "soap,  waste  disposal,  and  contaminated  clothing 

bags"  at  the  centers. 


Recommendations: 


1)  New  reception  centers  should  be  established  at  least  40  miles  from 
Pilgrim,  north  and  west  of  Boston. 

2)  These  should  be  adequate  to  accommodate  the  entire  permanent  and 
transient  population  in  the  EPZ. 

3)  Each  reception  center  should  stock  the  full  range  of  recommended  wash 
solutions  and  have  the  capability  of  collecting  contaminated  wash 
drainage. 


201 


Medical  Facilities 

A  core  meltdown  could  result  in  a  significant  release  of  radioactive 
gases  and  particulate  matter  into  the  air.   This  can  cause  genetic  mutations, 
cancer,  serious  injuries,  and  even  death  to  all  life  forms.   For  this 
reason,  federal  regulations  mandate  the  provision  of  special  medical  care 
for  contaminated  injured  indl  .-iduals .    The  only  two  hospitals  listed  as 

providers  of  any  medical  care,  however,  admit  they  have  the  capacity  to 

52 
treat  only  8  or  9  contaminated  persons.    One  of  these  hospitals,  moreover, 

is  only  3*1  ailea  from  the  plant  and  obviously  should  not  be  utilized. 

The  remaining  hospital  has  no  staff  trained  for  radioactively  contaminated 

53 
patients. 

As  a  suppleuBnt  to  treatment  at  medical  facilities  —  but  by  no  means 

a  substitute  —  potassium  iodide  (KI)  has  been  proven  safe  and  effective 

54 
against  radioactive  iodine  as  a  means  of  preventing  thyroid  tumors. 

Laboratory  workers  exposed  to  radioactive  iodine  have  taken  KI  for  many  years 
and  FEMA  guidelines  now  call  for  the  use  of  KI  in  the  event  of  a  nuclear 
accident. ^^  It  is  distributed  by  the  Tennesse  Valley  Authority  to  house- 
holds near  the  Sequoyah  reactor  and  throughout  all  EPZ's  In  Sweden. 
National  public  interest  organizations  including  the  Union  of  Concerned 
Scientists  and  the  Health  Research  Group  support  the  distribution  of  KI  to 

all  dwellings  in  the  EPZ  and  it's  availability  for  sale  over-the-counter 

56 
for  summer  residents  and  those  just  outside  the  EPZ. 


202 


-  36  - 


Recommendations: 


1)  Sufficient  medical  facilities  outside  the  EPZ  should  be  Ide 
to  care  for  large  numbers  of  contaminated  individuals. 

2)  All  emergency  personnel  should  receive  special  training  in 
treatment  of  radiation  victims. 

3)  Potassium  iodide  should  be  distributed  in  childproof  contai 
to  every  household  in  the  EPZ  before  a  nuclear  accident.  Inatr 
should  be  included  and  the  substance  should  be  sold  over-the-co 
as  well. 


Sheltering 

If  there  is  inadequate  time  to  evacuate  the  public  before  . 
of  radiation  passes  through  an  area,  the  recommended  protective  i 
shelter ing.^^  As  the  cloud  blows  downwind,  some  of  the  radloact 
material  or  "fallout"  is  deposited  on  the  ground  and  buildings  I 
If  a  substantial  amount  of  fallout  were  deposited  by  the  radioac 
cloud,  then  evacuation  would  be  ordered  as  soon  as  the  cloud  pa; 
order  to  minimize  additional  radiation  exposure. 

An  effective  sheltering  strategy  requires  both  protection  i 
gamma  radiation  emitted  from  the  passing  radioactive  cloud  and  f 
fallout  as  well  as  protection  against  inhalation  of  airborne  rac 
particles.  The  basements  of  large  buildings  and  of  brick  homes 
most  protection  from  gamma  radiation. ^^  But  where  are  45.000  su 
tourists  going  to  find  basements  in  large  buildings  or  brick  horn 


203 


37  - 


Wooden  motels  and  cabins  and  tents  provide  virtually  no  sheltering 
protection  from  a  radioactive  cloud,  and  the  24,000  sufflmer  residents 
typically  live  In  cottages  that  are  also  wooden  and  without  basements. 

In  fact,  even  for  the  54,000  full-time  residents,  there  are  few 
large  buildings  or  brick  homes  with  basements  In  the  Pilgrim  EPZ.   Fewer 
than  20Z  of  the  permanent  residences  In  Massachusetts  are  brick  ,  and 
about  30Z  of  the  year-round  homes  In  the  EPZ  have  no  basement.    Con- 
sequently #  a  substantial  majority  of  the  people  in  the  EPZ  lack  adequate 
sheltering  facilities. 

Civil  Defense  has  still  not  completed  a  survey  of  available  public 

shelters  in  the  EPZ.  Those  shelters  identified  already  are  not  marked 

62 
on  evacuation  maps  as  required  by  federal  guidelines. 

This  lack  of  sheltering  protection  is  compounded  by  the  failure  to 

educate  the  public  about  simple  building  infiltration  and  breathing  filter 

techniques.   Sheltering  studies  have  revealed  that  an  average  residence 

with  windows  and  doors  shut  reduces  the  amount  of  radionuclides  inhaled 

by  about  35Z.  Greater  protection  is  afforded  by  weatherstripping,  storm 

windows  and  doors,  and  the  taping  of  all  window  and  door  cracks  in  an 

emergency.   Further  protection  would  be  provided  by  the  use  of  individual 

respiratory  filters  such  as  hospital  masks  or  wet  towels  or  handkerchiefs. 

The  Emergency  Public  Information  pamphlet,  however,  makes  no  mention  of 

these  Important  protective  measures. 


204 


-  38 


Recommendations : 

1)   Civil  Defense  should  identify  enough  public  shelters  to  accommodate 
as  many  as  80,000  people  who  lack  basements  in  the  summer. 6* 

2)*  Public  sheltering  facilities  should  be  equipped  with  necessities  and 
clearly  marked  as  Civil  Defense  shelters.  Large  signs  should  be  erected 
directing  tourists  to  the  nearest  shelters. 

3)  The  location  of  public  sheltering  facilities  should  be  clearly 
designated  on  the  maps  in  the  Emergency  Public  Information  brochures, 
on  large  posters  and  in  telephone  book  inserts  distributed  throughout 
the  EPZ. 

4)  All  emergency  public  Information  materials  should  include 
sheltering  instructions,  including  techniques  for  making  home-made 
breathing  filters  and  reducing  radioactive  air  infiltration  into 
sheltering  facilities  or  homes. 

5)  Civil  Defense  should  distribute  hospital  masks  to  every  building  in 
the  EPZ.  ^5 


205 


-  39 


Emergency  Drills 

No  planB  with  the  complexity  of  evacuation  plans  could  ever  be 
carried  out  successfully  without  regular  and  comprehensive  drills.   Every 
year,  Boston  Edison  and  state  officials  hold  an  emergency  exercise 
simulating  a  meltdown  at  Pilgrim.   The  exercises  expose  liqjortant  defi- 
ciencies which  must  be  corrected,  but  they  are  still  not  sufficiently 
coi)H)rehen8lve  to  verify  the  capability  to  protect  the  public  in  the  event 
of  an  actual  meltdown. 

At  last  year's  drill,  FEMA  identified  many  deficiencies,  including 
inoperable  sirens,  failure  to  activate  an  emergency  broadcast  system 
station,  lack  of  equipment  for  measuring  radiation,  and  the  Issuance  of 
an  Incorrect  evacuation  order.    The  federal  evaluation  of  this  year'a 
drill,  held  June  29,  will  not  be  completed  for  several  weeks,  but  Civil 
Defense  and  FEMA  observers  admitted  there  were  significant  comminicatlon 
problems  at  least.    The  troubled  siren  system  will  not  be  tested  until 
FEMA  Issues  new  evaluation  criteria  later  this  year. 

A  more  serious  problem  la  the  failure  of  the  exercises  to  dencnstrate 
the  capability  to  warn,  mobilize,  evacuate,  and  decontaminate  the  public. 
Even  FEMA  has  conceded  this  point.    It  is  not  necessary  to  attempt  a 
full-scale  public  evacuation  to  establish  this  capability.   At  a  minimum, 
however,  all  sirens  should  be  tested,  sample  messages  broadcast  on  EBS, 
special  institutions  alerted  and  transportation  arranged  for  all  special 
population  groups  needing  assistance  within  the  sector  targeted  for 
evacuation.  This  is  an  excellent  occasion  to  educate  the  public  through 
the  media  of  the  details  of  sheltering  and  evacuation. 


206 


-  AO  - 


Another  problem  with  the  exercises  Is  the  comprehensive  prior 
planning  and  prenotif ication  of  emergency  personnel.   Federal  criteria 
require  occasional  unannounced  exercises  during  the  evening  and  night- 
time and  under  various  weather  conditions  which  more  accurately  test  the 
real  emergency  response  capability  of  officials. 

Recommendations: 


1)   Emergency  exercises  should  include  every  aspect  of  an  actual  emergency 
response,  except  evacuation  of  the  public.   Every  drill  should  include 
testing  of  all  sirens,  institutional  alarms  and  back-up  warning  capability; 
activation  of  the  EBS  system  and  broadcast  of  simulated  emergency  messages, 
arrangements  for  transportation  for  all  special  population  groups  within 
the  sector  targeted  for  evacuation,  and  bringing  in  some  buses  from  each 
participating  bus  company  to  report  to  a  special  institution  or  staging 
area  and  then  to  drive  the  evacuation  route  to  the  appropriate  reception 


2)  Drills  should  be  conducted  in  the  evening,  at  night,  under  various 
weather  conditions  and  seasons,  and  without  prior  warning. 


207 


41 


CONCLDSION 

Individually,  jmy  of  the  problems  with  current  emergency  planning 
Identified  in  this  report  is  serious;  collectively,  they  point  to  a 
crisis  situation  in  extreme  proportions.   Even  the  Director  of  the 
Plynouth  Civil  Defense  office,  James  Ryan,  has  admitted  "there  is  no 
way  that  everyone  can  be  evacuated." 

Besides  the  indefensible  danger  presented  by  the  emergency  plane, 

2 
violations  of  state  and  federal  law  are  involved.   The  plans  are  required 

to  provide  "reasonable  assurance  that  adequate  protective  measures  can 

and  will  be  taken  in  the  event  of  a  radiological  emergency."  The 

Massachusetts  Attorney  General  has  agreed  that  the  current  plans  fail  to 

do  this  and  has  urged  that  consideration  be  given  to  the  operation  of 

Pilgrim  at  reduced  power  or  even  shut  down  during  the  summer,  when  the 

3 
area  is  clogged  with  visitors  whose  lives  are  in  jeopardy. 

MASSPIRG  has  submitted  a  formal  petition  to  the  Nuclear  Regulatory 

Commission  requesting  immediate  remedial  measures,  including  consideration 

of  shutting  down  Pilgrim  until  an  adequate  state  of  emergency  preparedness 

-  4 
is  achieved.   Given  the  NRC's  recent  refusal  to  enforce  emergency  planning 

regulations  under  similar  conditions  at  the  Indian  Point  reactors  in 

3 

New  York  ,  though,  it  will  no  doubt  fall  to  the  Conmionwealth  to  protect 

its  citizens.  MASSPIRG  therefore  urges  the  Governor  to  establish  a  public 
emergency  planning  commission  to  oversee  the  revision  of  these  plans  for 
Pilgrim  (and  for  the  area  near  the  Rowe  reactor,  to  the  extent  its  problems 
are  similar).   The  state  also  should  commission  an  emergency  mass  transpor- 


208 


42 


tatlon  study,  a  new  calculation  of  evacuation  time  estimates,  and  a 
computer  analysis  of  the  consequences  of  major  meltdowns  with  an  eye 
to  expanding  the  emergency  planning  zone  to  Include  Cape  Cod  and 
other  areas  near  the  Plymouth  plant.   Until  these  recomnwndatlons  are 
Implemented  —  until  the  egregious  Inadequacy  of  current  planning  is 
acknowledged  and  corrected  —  the  lives  of  thousands  of  citizens  will 
remain  at  risk. 


! 


209 

-  43  - 

FOOTNOTES 
OVERVIEW 

1.  MASSPIRG  Survey  of  Major  Campgrounds,  Appendix  B. 

2.  "Interim  Findings:  Joint  State  and  Local  Radiological  Emergency  Response 
Capabilities  for  the  Pilgrim  Nuclear  Power  Station"  ("FEMA  Interim  Findings") , 
FEMA,  September  1982. 

3.  "Planning  Basis  for  the  Development  of  State  and  Local  Government  Radiological 
Emergency  Response  Plans  in  Support  of  Light  Water  Nuclear  Power  Plants," 
("Planning  Basis"),  mJREG-0396,  EPA/NRC.  December  1978,  p,  20.  Also  see 
Chapter  IV:   Evacuation  Plans. 

4.  See  Chapter  IV:   Sheltering. 

5.  "Three  Mile  Island:  Report  to  the  Commissioners  and  to  the  Public"  ("NRC 
Special  Inquiry  Group  Report"),  NRC  Special  Inquiry  Group,  1980,  p.  132. 

6.  "Report  of  the  President's  Commission  on  the  Accident  at  Three  Mile  Island" 
("Report  of  the  President's  Commission"),  October,  1979,  pp.  76-77  (emphasla 
in  original);  NRC  Special  Inquiry  Group  Report,  op.  cit.  pp.  131-133. 

7.  The  NRC  defines  a  "worst-case  accident"  as  the  worst  accident  considered 
theoretically  possible  at  a  nuclear  power  plant.   It  may  be  worth  noting, 
however,  that  the  accident  at  Three  Mile  Island  was  considered  "not  credible"  - 
which  is  to  say,  impossible  -  before  it  actually  happened. 

8.  "Calculation  of  Reactor  Accident  Consequences  ("CRAG  2")  For  U.S.  Nuclear 
Power  Plants  (Health  Effects  and  Costs)  Conditional  on  an  SSTI  Release," 
U.S.  House  of  Representatives  Committee  on  Interior  and  Insular  Affairs, 
Subcommittee  on  Oversight  and  Investigations,  November  1,  1982,  p.  9. 

9.  NRC  Special  Inquiry  Group  Report,  op.  cit.,  p.  91. 

10.  "Precursors  to  Potential  Severe  Core  Damage  Accidents"  ("Precursors"), 
NUREG/CR-2497,  Oak  Ridge  National  Laboratories,  1982. 

11.  Report  of  the  President's  Coimnission,  op.  cit.,  p. 7. 

12.  "PrecuTBors,"  op.  cit. 

13.  "Systematic  Assessment  of  Licensee  Performance,"  NUREG-0834,  1981; 
NRC  memo  from  Gus  Lalnas,  Assistant  Director  for  Safety  Assessment,  to 
Darrell  Elsenhut,  Director,  Division  of  Licensing,  "Summary  of  the 
Operating  Reactor  Events  Meeting  on  December  16,  1981 ,"  December  28,  1981. 
(These  safety  rankings  are  based  on  both  the  number  and  severity  of  mishaps 
between  December  13,  1980  and  October  7,  1981. 

14.  Letter  to  F.M.  Staszesky,  President,  Boston  Edison  Company  from  Richard  C. 
DeYoung,  Director,  NRC  office  of  Inspection  and  Enforcement,  NRC  Docket 
No.  50-293  (January  18,  1982). 

15.  NRC  SEeclal  Inquiry  Group  Report,  op.  cit.,  p.  131. 


210 


44  - 


'16.   Roport  of  the  President's  Commission,  op.  cit.,  p.  76. 

17.  10  CFR  §50.47  and  Part  50,  Appendix  E. 

18.  10  CFR  i50.54(s)(2)(i). 

19.  44  CFR  §350. 5(b)  (proposed  rule;  current  FEMA  guidelines); 
10  CFR  §50.4:(a)(l). 

20.  10  CFR  §50. 47(c)(1). 

21.  "In  the  Matter  of  Consolidated  Edison  Company  of  New  York  and 
Power  Authority  of  the  State  of  New  York  (Indian  Point  2  &  3)", 
CLI-83-16,  June  10,  1983. 

22.  "Interim  Findings,"  op.  cit.,  pp.  1,5. 


I.   THE  EMERGENCY  PLANNING  ZONE 

1.  10  CFR  §50. 47(c)(2)  ;  44  CFR  8350. 7.(b)  (current  guidelines). 

2.  Planning  Basis,  op.  cit.  ;  "Massachusetts  Radiological  Emergency  Response 
Plan  ("State  Plan"),"  Appendix  3  -  Pilgrim,  pp.  C-78-79.   (The  Environmental 
Protection  Agency  recommends  evacuation  when  the  expected  radiation  dose  to 
the  public  is  one  "REM".   A  REM  is  a  unit  of  measuring  radiation  exposure 
and  is  the  equivalent  of  receiving  about  10  x-rays.) 

3.  Planning  Basis,  op.  cit. 

4.  "CR/-.C  2,"  op.  cit. 

5.  Report  of  the  President's  Commission,  op.  cit.,  p.  40. 

6.  "Emergency  Planning  Zones  for  Serious  Nuclear  Power  Plant  Accidents," 
California  Office  of  Emergency  Services,  November  1980. 

7.  The  Planning  Basis  report,  op.  cit.,  was  written  in  1978  and  used  the 
probability  estimates  of  the  1975  Reactor  Safety  Study.  More  recent 
studies  indicate  a  higher  probability  of  accidents  (Precursors,  op.  cit.) 
and  more  serious  consequences  from  them  (CRAC  2,  op.  cit.). 

8.  "Planning  Basis,"  op.  cit.,  p.  16. 

9.  "Response  of  Boston  Edison  to  Commonwealth  of  Massachusetts'  First  Set  of 
Interrogatories  on  Emergency  Planning,  "  July  20,  1981,  p.  2. 

10.  "NRC  Special  Inquiry  Group  Report,"  op.  cit.,  p.  1016. 

11.  "A  Public  Meeting  on  the  State  and  Local  Off-Site  Radiological  Emergency  Plan,' 
Transcript  of  Hearing.   ("Transcript  of  Public  Hearing"),  Plymouth,  Mass., 
June  3,  1932,  statement  by  Baul  Cahill,  then  Director.  Mass.  Civil  Defense 
Agency,  p.  109. 


211 


45 


12.   "Comments  of  Attorney  General  Francis  X.  Bellottl  Relative  to  Off-Site 

Emergency  Planning  for  the  Pilgrim  Nuclear  Power  Station,"  ("Coainents  of  the 
Attorney  General"),  submitted  to  FEMA,  August  1982,  pp.  11-13. 


II.  ADVANCE  INFORMATION  TO  THE  PUBLIC 

1.  "The  Social  and  Economic  Effects  of  the  Accident  at  Three  Mile  island," 
C.B.  Flynn  and  J. A.  Chalmers,  1980,  p.  22.   (About  20,000  people  evacuated 
from  Three  Mile  Island  before  any  order  was  Issued.)   On  the  other  hand,  the 
MASSPIRG  Survey  also  revealed  that  7Z  of  respondents  would  not  evacuate 
even  if  ordered  to  do  so  (Appendix  A,  l?32).   Twenty  percent  of  respondents 
in  the  Shoreham  EPZ  said  they  would  not  evacuate.   ("Discussion  Overview 

of  the  RERP  of  the  County  of  Suffolk,"  Philip  B.  Herr  &  Associates, 
Nov.  29,  1982,  p.  15.) 

2.  Criteria  for  Preparation  and  Evaluation  of  Radiological  Emergency  Response 
Plans  and  Preparedness  In  Support  of  Nuclear  Power  Plants ("Evaluation 
Criteria"),  NUREG-0654,  Rev.  1,  Evaluation  Criteria  G. 1. ,G. 2. 

.  3.  Evaluation  Criterion  G.l. 

'4.  State  Plan,  op.  cit.,  p.  C-9. 

.  5.   FEMA  Interim  Findings,  op.  cit.,  p.  6. 

6.  Phone  conversation  with  Gerald  Hayes,  former  Plynouth  Civil  Defense  Director. 
July  12,  1982. 

7.  MASSPIRG  Survey  of  Residents,  Appendix  A,  l?23,  )?28. 

8.  MASSPIRG  Survey  of  Residents,  Appendix  A,  //16, 

9.  Nuclear  Energy  -  Questions  and  Answers,  p.  4. 
■10.   MASSPIRG  Survey  of  Residents,  Appendix  A,  #43. 

11.  MASSPIRG  Survey  of  Residents,  Appendix  A,  #32 

12.  Town  of  Plymouth  Radiological  Emergency  Response  Plan  ("Plynouth  Plan"),  p.  36. 
Emergency  Public  Information,  p. 6. 

13.  Plymouth  Plan,  op.  cit.,  p.  ANN.  B-9. 

14.  MASSPIRG  Survey  of  Local  Civil  Defense  Directors,  Appendix  C. 

15.  MASSPIRG  Survey  of  Correctional  Facilities,  Appendix  D;  Interim  Findings, 
op.  cit.,  pp.  15-16. 


16. 


MASSPIRG  Survey  of  Local  Civil  Defense  Directors,  Appendix  C. 


212 


46  - 


17.  '  MASSPIRG  Survey  of  Local  Civil  Defense  Directors,  Appendix  C. 

18.  FEMA  Interim  Findings,  op.  cit.,  p.  6;  Evaluation  Criterion  P. 10. 

19.  State  Plan,  op.  cit.,  p.  C-21. 

20.  Evaluation   Criterion   G.2. 

III.      NOTIFICATION  DURING  AN  ACCIDENT 

1.  "Planning  Basis,"  op.    cit.,    p.    20. 

2.  Letter  from  Richard  Starostecki,  Director,  Division  of  Project  and  Resident 
Programs,  NRC,  to  Boston  Edison,  dated  Septeniber  28,  1982,  Appendix  A: 
Notice  of  Violation. 

3.  10  CFR  Part  50,  Appendix  E,  IV,  D.3. 

4.  Evaluation  Criterion  E.6.  and  NUREG-0654,  Appendix  3,  p.  3-3. 

5.  Report  on  the  Coverage  and  Performance  of  Sirens  Around  the  Pilgrim 
Nuclear  Pover  Station  ("HUM  Siren  Report") ,  HUM  Associates,  July  15,  1982, 
pp.  2-6  -  2-7. 

6.  Report  on  the  Pilgrim  Nuclear  Power  Station  Siren  Test,  June  19,  1982 
("FEMA  Siren  Report"),  FEMA,  January  1983,  p. 6. 

7.  HMM  Siren  Report,  op.  cit.,  pp.  8-3,  4-7. 

8.  FEMA  Siren  Report,  op.  cit.,  pp.  11,  10. 

9.  MASSPIRG  Survey  of  Residents,  Appendix  A,  ff7 ,    (?13. 

10.  FEMA  Siren  Report,  op.  cit.,  p.  11. 

11.  Letter  from  Lee  Thomas,  Acting  Deputy  Director,  FEMA,  to  William  Dircks, 
Executive  Director  for  Operations,  NRC,  dated  December  17,  1982. 

12.  FEMA  Siren  Report,  op.  cit.,  p.  9. 

13.  MASSPIRG  Survey  of  Residents,  Appendix  A,  HS,    1119. 

14.  FEMA  Siren  Report,  op.  cit.,  p.  8. 

15.  MASSPIRG  Survey  of  Residents,  Appendix  A,  1116. 

16.  MASSPIRG  Survey  of  Residents,  Appendix  A,  l?29. 

17.  MASSPIRG  Survey  of  Correctional  Facilities,  Appendix  D, 


213 


47  - 


18.  FEMA  Interim  Comments,  op.  clt..  p.  15. 

19.  Evaluation  Criteria  E.5,  E.6. 

.20.  Transcript  of  Public  Hearing,  June  3.  1982,  pp.  79-86. 

21.  FEMA  Exercise  Report,  op.  clt.,  p.  54. 

22.  7%  (:59,000  deaf  and  335,000  with  serious  hearing  impairments  out  of 
5,737,037  total  residents)  of  Massachusetts  residents  have  serious 
hearing  deficiencies.   Although  deaf  people  tend  to  congregate  in  urban 
areas,  it  is  reasonable  to  estimate  that  2Z  (54,000  permanent  residents 
in  EPZ)  or  1000  residents  have  serious  hearing  problems  in  the  EPZ. 

23.  Criteria  J.lO.c,  E.6.  ;  10  CFR  Fart  50,  Appendix  E,  IV. D. 3. 

24.  State  Plan,  op.  clt.,  p.  C-24. 

25.  State  Plan,  op.  clt.,  p.  C-24  -  C-25. 

26.  Teletypvriters  (TTY's)  transmit  typewriter  messages  over  phone  lines 

with  warning  lights  that  signal  receipt  of  a  message.   In  the  past,  Boston 
Edison  offered  to  provide  TTY's  to  deaf  persons  in  the  EPZ.   California 
has  provided  TTY's  to  all  deaf  persons  In  the  state. 


IV.   EVACUATION  PLANS,  SHELTERING,  AND  OTHER  PREPARATIONS 

1.  Plymouth  Plan,  op.  clt.,  pp.  5-6. 

2.  NUREG-0654,  p.  17. 

3.  "An  Evaluation  of  the  Evacuation  Time  Estimates  Submitted  by  the  Applicant 
for  a  Peak.  Population  Scenario  at  the  Pilgrim  II  Nuclear  Power  Station," 
E.P,  Moeller,  T.  Urbanlk  II,  and  A.E.  Desrosiers.  March  1981,  p.  5. 

4.  State  Plan,  op.  clt.,  p.  C-86  (South  10  Miles  -  Normal  Weather). 

5.  "Evacuation  from  a  Nuclear  Technological  Disaster,"  D.J.  Zlegler,  S.D.  Brunn 
and  J.H.  Johnson,  Jr.,  The  Geographical  Review,  January  1981,  p. 7. 

6.  "Seabrook  Station  Evacuation  Analysis,"  ("Seabrook  Analysts'!)  Voorhuis  and 
Associates,  August  1980,  p.  63. 

7.  Seabrook  Analysis,  p.  74;  "Dynamic  Evacuation  Analyses:   Independent 
Assessments  of  Evacuation  Times  from  the  Plume  Exposure  Pathway  Emergency 
Planning  Zones  of  Twelve  Nuclear  Power  Stations,"  FEMA-REP-3,  1981,  p.  46. 


214 


-  48  - 

8.   Exercise  Report  -  Joint  State  and  Local  Radiological  Emergency  Response 
Exercise  for  the  Pilgrim  Nuclear  Power  Station,  March  3,  1982  ("FEMA 
Exercise  Report"),  FEMA,  Septerier  1982,  p.  45. 

■  9.   Evaluation  Criteria  J. 8.,  J. 10.1.,  and  Appendix  U,   pp.  4-3,  4-6,  4-7,  4-9,  4-10. 

10.  State  Plan,  op.  cit.,  p.  C-86. 

11.  "Comments  of  Attorney  General  Francis  X.  Bellotti  Relative  to  Off-Site 
Emergency  Planning  for  the  Pilgrim  Nuclear  Power  Station"  ("Comments  of  the 
Attorney  General"),  submitted  to  FEMA,  August  1982,  pp.  7-9,. 

12.  Plymouth  Plan,  op.  cit.,  p.  8. 

13.  MASSPIRG  Survey  of  Residents,  Appendix  A,  #34. 

14.  Town  of  Plynouth  Planning  Board  Survey,  1979;  MASSPIRG  Survey  of  ReBidents, 
Appendix  A,  #6. 

15.  Emergency  Public  Information  Pamphlet,  p.  6. 

16.  FEMA  Exercise  Report,  op.  cit..  p.  45. 

17.  Evaluation  Criteria  A.3.  andC.4. 

18.  To  evacuate  14,000  people  in  buses  with  a  capacity  of  40  persons  would 
require  about  350  buses.  Evacuation  buses  would  not  have  room  for  much  more 
than  their  capacity  of  40  people  because  evacuees  are  directed  to  bring  extra 
clot. ling  and  necessities.  The  civil  defense  estimate  that  only  about 

50  buses  would  be  needed  is  clearly  inadequate  [FEMA  Exercise  Report,  p.  45]. 
Civil  defense  also  relies  on  carpooling  too  much  [Plymouth  Plan,  p.  8], 
There  simply  won't  be  that  much  extra  room  In  the  family  car  after  the  family, 
pets  and  clothing  are  stuffed  into  cars  which  are  becoming  smaller  and  smaller. 

19.  "Response  of  Emergency  Personnel  to  a  Possible  Accident  at  the  Shoreham 
Nuclear  Power  Plant,"  Social  Data  Analysis,  Inc.,  October  1982;  "Update 
Report  on  the  Status  of  Remedial  Actions  Cited  in  the  July  30,  1982  Interim 
Findings  on  the  Adequacy  of  Radiological  Emergency  Rebponse  Preparation  of 
State  and  Local  Governments  at  the  Indian  Point  Nuclear  Power  Station," 
("Update  Report  on  Indian  Point,"),  December  1982,  p.  6. 

20.  Evaluation  Criterion  J.lO.d;  The  MASSPIRG  Survey  of  Residents  discovered  that 
6X  of  households  in  the  EPZ  had  physically  disabled  people.   62  of  20,000 
households  in  the  EPZ  (1980  Census)  is  1200  handicapped  persons. 

21.  State  Plan,  op.  cit.,  pp.  22-23. 

22.  Plymouth  Plan.  op.  cit.,  pp.  39-40. 

23.  MASSPIRG  Survey  of  Ambulance  Services,  Appendix  E. 

24.  MASSPIRG  Survey  of  Ambulance  Services,  Appendix  E. 


215 

-  49  - 

25.  FEMA  Interim  Findings,  op.  cit..  p.  6. 

26.  MASSPIRG  Surveys  of  Nursing  Homes  (Appendix  F) ,  Campgrounds  (Appendix  B) 
and  Correctional  Facilities  (Appendix  D). 

27.  Plymouth  Plan.  op.  cit..  p.  38. 

28.  Plymouth  Plan,  op.  cit..  p.  36. 

29.  Emergency  Public  Information  pamphlet,  p.  6. 

30.  MASSPIRG  Survey  of  Nursing  Homes,  Appendix  F. 

31.  Conversation  with  Frank.  Willard.  the  Director  of  MCDA  Area  II  Headquarters 
in  Bridgewater,  February,  1983. 

32.  Plymouth  Plan,  op.  cit..  p.  39;  Emergency  Public  Information  pamphlet,  p.  6. 

33.  MASSPIRG  Survey  of  Correctional  Facilities,  Appendix  D. 
3A,   FEMA  Exercise  Report,  op.  cit..  p.  25. 

35.  Update  Report  on  Indian  Point,  p.  6. 

36.  MASSPIRG  Survey  of  Campgrounds,  Appendix  B. 

37.  Conversation  with  Frank  Willard,  Director  of  MCDA  Area  II  Headquarters  in 
Bridgewater,  May,  1983. 

38.  Transcript  of  Public  Hearing,  June  3,  1982,  Statement  by  Paul  CahlH,  former 
Director  of  the  Mass.  Civil  Defense  Agency,  p.  109. 

39.  Conversation  with  Jane  Peterson,  Cape  Cod  Chamber  of  Commerce,  February  8,  1983, 

40.  See  Chapter  I,  supra,  p.  7. 

41.  Warning  sirens  are  only  located  within  the  10-mile  EPZ. 

42.  US  Census,  1970  (basement  data  not  collected  in  1980  census). 

43.  State  Plan,  op.  cit..  pp.  C-17  -  C-19;  Annex  E,  pp.  C-101  -  C-113. 

44.  State  Plan,  op.  cit..  p.  C-17. 

45.  Total  summer  population  of  the  EPZ  is  about  120.000,  divided  among  3  reception 
centers  results  in  roughly  40,000  evacuees  per  reception  center. 

46.  Evaluation  Criterion  J.  12. 

47.  FEMA  Exercise  Report,  op.  cit..  p.  31. 

48.  State  Plan,  op.  cit..  Annex  E.  C-102  -  C-103. 

49.  State  Plan,  op.  cit..  C-70  -  C-72. 


216 


-so- 
so.  FEMA  Interim  Findings,  op.  clt..  p.  9. 

51.  10  CFR  §  50.47(b) (12);  10  CFR  Part  50,  Appendix  E,  II. E  and  IV. E. 7. 

52.  MASSPIRG  Survey  of  Hospitals,  Appendix  G. 

53.  MASSPIRG  Survey  of  Hospitals,  Appendix  G. 

54.  43  Federal  Register  58798,  December  15,  1978. 

55.  Evaluation  Criterion  J.  lO.e.  and  J.lO.f. 

56.  "Submission  for  the  Record:   Hearing  on  Potassium  Iodide  as  a  Thyroid  Blocking 
Agent  in  a  Radiation  Emergency,"  Gordon  Thompson,  Ph.D.,  Union  of  Concerned 
Scientists,  submitted  to  the  U.S.  House  of  Representatives  Committee  on 
Interior  and  Insular  Affairs,  Investigations  and  Oversight  Subcommittee, 
March  5,  1982.   The  Mass.  Department  of  Public  Health  opposes  distribution 

of  KI  to  the  public.   The  advantages  of  KI  far  outweigh  the  disadvantages. 
None  of  DPH's  arguments  against  use  of  KI  override  the  protection  that  KI 
can  provide  from  radiation  exposure. 

The  logistical  problem  of  distributing  KI  after  an  accident  has  been  solved  by 
the  Tennessee  Valley  Authority  by  simply  distributing  proper  doses  of  the 
drug  to  residents  within  the  EPZ  before  a  meltdown  occurs.   The  directions 
will  indicate  the  dose  and  emergency  officials  will  announce  when  to  take 
the  KI.   Childproof  caps  would  prevent  unsupervised  Ingestion  by  kids. 

The  side  effects  anticipated  from  the  recommended  dosage  for  radloprotectlon 
will  be  very  minimal.   Side  effects  occasionally  appear  after  years  of  KI 
use  at  doses  of  300  mg  to  1200  mg  per  day.   But  for  radiation  protection, 
adults  would  take  only  130  mg  per  day .  for  10  days,  and  kids  Just  65  mg  per 
day. 

A  few  recent  studies  have  suggested  that  anticipated  releases  of  radioactive 
iodine  during  a  reactor  accident  may  be  much  lower  than  originally  expected. 
The  NRC,  however,  conducted  a  substantial  investigation  in  1981  that  concluded 
that  although  the  Reactor  Safety  Study  may  have  overestimated  the  iodine 
that  would  be  released  from  small  accidents,  the  original  estimates  are 
probably  still  valid  for  the  larger  accidents.   ["Technical  Bases  For 
Estimating  Fission  Product  Behavior  During  LWR  Accidents,"  NUREG-0772, 
June,  1981.1 

The  last  issue  concerning  KI  is  whether  stockpiling  the  drug  for  distribution 
during  an  accident  would  be  preferable  to  predistributing  KI  to  all  households 
in  the  EPZ.   Attempting  to  distribute  KI  to  all  potentially  affected  households 
after  an  accident  began  would  be  a  logistic  nightmare  if  not  physically  impossible 

57.  Plymouth  Plan,  op.  clt.,  pp.  5-6. 

58.  "Public  Protection  Strategies  for  Potential  Nuclear  Reactor  Accidents: 
Sheltering  Concepts  with  Existing  Public  and  Private  Structures,"  (SAND77-1725 
D.C.  Aldrich,  D.M.  Erlcson,  Jr.,  J.D.  Johnson,  Sandla  Laboratories,  1978, 

p.  10. 


217 


51 


59.  Population  figures  are  from  the  State  Plan,  op.  clt.,  p.  C-9. 

60.  SAND77-1725,  p.  26. 

61.  1970  Census  Data  (basement  data  not  collected  in  1980). 

62.  Evaluation  Criterion  J. 10. a. 

63.  "Public  Protection  Strategies  In  the  Event  of  a  Nuclear  Reactor  Accident" 
(SAND77-1555)  D.C.  Aldrich,  D.M.  Ericson,  Jr..  Sandia  Laboratories,  1978, 
pp.  40,  42-43. 

64.  There  are  45,000  tourists  on  summer  weekends.   There  are  24,000  seasonal 
residents  of  which  close  to  20,000  probably  have  no  basement  in  their 
cottages.   30Z  of  the  54,000  permanent  residents  don't  have  basements 
about  15,000  people. 

65.  100,000  hospital  masks  for  distribution  in  the  EPZ  would  cost  $19,090 
from  American  Scientific  Products,  according  to  sales  representative  Mike 
Govern.  (Centura  Mask  -  685-N) 

66.  FEMA's  Interim  Findings,  op.  cit.,  pp.  15,17.18;  Exercise  Report,  op.  clt., 

p.  54. 

67.  Conversation  with  Bob  Archlla,  FEMA,  July  13,  1983. 

68.  FEMA's  Interim  Findings,  op.  cit.,  p.  18. 

69.  Evaluation  Criterion  N.l.b. 

70.  Buses  drive  actual  evacuation  routes  during  drills  for  the  Indian  Point 
reactors,  "Post  Exercise  Assessment  (Indian  Point),"  FEMA,  April  14,  1983. 
p.  14. 


CONCLUSION 

1.  MASSPIRG. Survey  of  Civil  Defense  Directors,  Appendix  C. 

2.  The  failure  to  maintain  adequate  emergency  response  plans  for  a  nuclear 
accident  is  a  violation  of  the  Mass.  Civil  Defense  Agency's  responsibility 
to  protect  the  citizens  of  the  Commonwealth.   Mass.  General  Laws,  Appendix 
to  Chapter  33,  Section  13.   Federal  law  also  requires  workable  plans: 

10  CFR  8  50.47(a) (1)(NRC)  and  44  CFR  g  350.5(b) (FEMA) . 

3.  Comments  of  the  Attorney  General,  op.  cit.,  pp.  1,  14-15. 

4.  Petition  of  Massachusetts  Public  Interest  Research  Group  for  Emergency  and 
Remedial  Action,  July  18,  1983. 

5.  "In  the  Matter  of  Consolidated  Edison  Company  of  New  York  and  Power  Authority 
of  the  State  of  New  York  (Indian  Point  2  &  3),"  CLI-83-16,  June  10,  1983. 


218 


APPENDIX  A 

MASSPIRG  Survey  of  Residents  in  the  Emergency  Planning  Zone 

MASSPIRG  conducted  a  telephone  survey  of  100  residents  of  the 
Emergency  Planning  Zone  (EPZ) .   The  survey  was  designed  and  supervised 
by  Martha  Downey  of  Decision  Research  Corporation  of  Lexington,  Mass, 
Respondents  were  selected  at  random  from  local  telephone  books  for 
Plymouth,  Duxbury,  and  Kingston.  The  number  of  respondents  from  each 
town  was  determined  by  the  populations  of  each  town  so  the  results  are 
applicable  to  the  full  EPZ,   (Plymouth  (pop.  35,913):  64  respondents, 
Diixbury  (11,807):  22  respondents,  and  Kingston  (7,362):  14  respondents), 
Half  the  respondents  from  each  town  were  men  and  half  women.  MASSPIRG 
volunteers  conducted  the  survey  between  February  and  May,  1983. 


219 


Telephone  Survey  of  100  Raaidencs  In  the  Eaergency  Planning  Zone:   Sunaiery  of  Reeulcs 
Queedon 


1.   Local  fire  response  capability? 


2.   Quality  of  fire  personnel  and 
equipment? 


Anbulance  response  capability? 


^>   Quality  of  anbulance  personnel 
and  equlpnent? 


5.   Work  Indoors  at  office  or  building 
other  than  your  residence? 

(If  "no"  or  "unsure"  proceed  to  #8) 


6.   Where  Is  office  or  building 
located? 


Hear  sirens  when  at  work  with 
windows  and  doors  closed? 


8.   Hear  sirens  at  residence  with 
windows  and  doors  closed? 


9.   Aware  of  any  other  public 
emergency  warning  systems? 


Very  Good 

Good 

Fair 

Poor 

Unaure 

Very  Good 
Good 
Fair 
Poor 

Unsure 

Very  Good 

Good 

Fair 

Poor 

Dnsure 

Very  Good 
Good  . 
Fair 

Poor 
Unsure 

Tea 

Ho 
Unsure 

Kesldence 

Plyscuth, 
Dux.,  King 

Outside 
EFZ 

No  Job/ 
Unsure 

Yes 
No 

Unsure 

Yes 
Ho 

Unsure 

Pilgrim 
Other 
No 
Unsure 


Plysuuth        Kingston  Duxbury 

64  Respondents   U  Res.   22  gas.   Totsl 


24 

26 

2 

1 

II 

27 

21 

4 

0 

12 

21 

22 

4 

1 

16 

12 

21 

7 

0 

24 

32 

32 

0 

12 
4 

10 
7 

12 

U 

1 

53 

11 
0 

55 
2 
5 

8 


5 
5 

0 
0 

4 

5 
7 
0 
0 
2 

5 
5 
1 
0 
3 

3 
6 
2 
0 
3 

9 
5 
0 

2 
2 
3 
1 

3 
1 
0 

13 
I 
0 

12 
0 
2 
1 


11 
7 
0 
0 
4 

8 
8 
0 
0 
6 

14 
3 
0 
0 
5 


u 

26 

3 

30 

0 

9 

0 

0 

8 

35 

13 

54 

9 

46 

0 

0 

I 

15 

4 

10 

8 

21 

0 

8 

3 

18 

4 

16 

1 

2 

17 

83 

2 

14 

I 

1 

20 

87 

I 

3 

1 

8 

4 

13 

40 

38 

2 

1 

19 

40 

36 

4 

0 

20 

40 

30 

5 

1 

24 


220 


Talephon*  Survay  of  100  Xesldants  In  ch« 
Qu««tlon 


crgcncy  Planning  Zon«; 


Sui 


■ry  of  Xtculta 


10.   If  ooc,  aware  of  the  Pilgrim 
warning? 


II.   What  doea  the  Pilgrim  siren 
mean? 


Plymouth        Xingaton  Duxbury 

<*  Raapondenta   14  Raa.   22  Rea.   Total 


12.   Ever  heard  a  Pilgrim  warning 
alren  from  home  or  job? 

(If  "no"  or  "unsure"  proceed 
to  #16) 


13.   Can  the  Pilgrim  alren  be  heard 
veil  when  vlndowa  and  doors 
art  closed? 


T«s 

Ho 
Unsure 

Accident 
or  warning 

Drill  or 
test 

Malfuncxion 

Other 

Unsure 

Home 

Job 

No 

Unsure 


(Home) 


Well 

Not  well 
Not  at  all 
Unsure 


(Job) 

Well 

1 

Not  well 

2 

Not  at  all 

4 

Unsure 

1 

u. 

Know  location  of  nearest 
siren? 

(Home) 

Yes 

40 

No 

" 

Unsure 

3 

(Job) 

Yea 

3 

No 

0 

Unsure 

1 

IS.  How  far  Is  the  alren? 
(Home) 


<l/2   mile 

between   1/2  mile  &    1   nile 

>1   mile 

Unsure 

Reaponse  not  credible 


27 

2 

21 

1 

8 

49 
4 

12 
0 


27 

19 

7 

0 


26 

10 

7 


10 


1 

2 

1 

0 

2 

1 

1 

4 

12 

16 

3 

0 

2 

4 

0 

2 

15 


8 

10 

3 

3 

1 

2 

0 

2 

3 

0 

1 

0 

0 

1 

0 

I 

7 

12 

5 

6 

0 

1 

2 

3 

1 

0 

0 

0 

221 


TtXcphen«  Surwy  of    100  Htddaacs   la  th*  Eacrgaacy  Planning   Zona:      Suanary  of   ILaaulta 


Quaatlon 


Plyaouth       Klngiton  Duxbury 

6*  Kaapondanta   U  Kaa.   22  Rai.  Total 


22. 


15.   (continued) 

Row  far  la  tha  a Iran? 


(Job)  ^1/2  Bila 

batwaan  1/2  mIIc  (  1  idla 

>  1  Blla 

Unaure 

Reaponaa  not  credlbla 


16.      First  reaction  to  Pilgrim  alrcn. 
If  not  drUlT 


Evacuate 
Shcltar 
Radio  or  T.V. 
Eaerifancy   Broadcast   Syatea  atatlon 

Ignore 

Unaura 

Teat  or  aalfunctlon 

Call  police 

other 


17.     Can  you  naaa  an  Ea«rgency  Broadcaat 
,  Syataa  station? 


18.     Ever  heard  Pllgrla  alran  go  off 
accidentallyT 

(If  "no"  or  "unaura"  proceed   to   120) 


Yea 

Ho 

Yea 

Ito 
Unaura 


19.      How  aany   tlaaa? 


1 

2 

3-7 

8  or  Bore 

Call  soaeone 

Radio  or  T.V. 

Other 

Unaure 

Great  deal 

Sone 

Not  Buch 

None 

Unsure 


How  did  you  learn  what  you  know  Media 

about  emergency  procedures?    „.,.  .  ,  .   . 

"  Official  Brochure 

Word  of  Bouth 

Other 


20.   How  would  you  determine  whether  a 
alren  was  a  falaa  alar«7 


21.  How  much  do  you  feel  you  know 
about  eacrgency  procaduree  In 
case  of  an  accident  at  Pilgrim? 


1 
0 
0 
I 
0 

5 
5 

12 

6 
10 
12 

7 

6 

3 

40 
2* 

51 
9 
1 

8 

7 

2S 

9 

19 

28 

9 

10 

4 
19 
28 
II 

1 

19 
24 
.7 
14 


0 
3 
7 
I 

2 
8 

1 
3 

0 
3 
8 

3 

0 

s 

3 

1 

4 


10 


3 

2 
1 
1 
0 

7 

7 
19 

9 
17 
17 
13 

7 


59 
41 

77 

18 

2 

10 
15 
39 
11 

29 
46 
11 
17 

6 
29 

44 
16 

4 

32 
35 

11 
21 


222 


Ttlcphon«  Survay  of  100  Kaddcnti  In  ch«  Energcncy  Planning  Zone:   Suarury  of  Raiulcs 
Qu«»tlon 


Plyaouch        Kingston  Duxbury 

64  Ke«pond«nti   U  R««.   22  Res.  ^ot») 


23.   Haim  you  received  Emergency  Public 
Informadon  Brochure? 

(If  "no"  or  "unsure"  proceed  to  *29) 


29. 


24, 


When? 


25.   Did  you  read  the  brochure? 


26.   Was  It  helpful? 


27.   Do  you  have  the  brochure 
available  right  now? 


28.  Where  is  It  kept? 


Any  questions  regarding 
emergency  planning? 

*  The  response  of  one  Plymouth  man  was 
"Why  can't  they  ia^rove  the  sirens  so 
people  uould  believe  them?" 


30.  Dangerousness  of  accident  at  Pilgrim? 


Yes 

45 

No 

16 

9)      Unsure 

Z 

Sept  "82" 

3 

Oct  "82" 

0 

Fall  "82" 

6 

Other  "82" 

a 

Fall  "81" 

0 

Other 

5 

Unsure 

20 

Completely 

24 

Partially 

16 

Not  at  all 

5 

Very 

11 

Somewhat 

25 

Not  at  all 

6 

.Unsure 

1 

Yas 

16 

No 

29 

Location  given 

14 

Unaure 

8 

Yes 

23 

Ho 

41 

31.  What  is  the  safest  location? 


Igrim?      Very 

27 

Somewhat 

23 

Not  at  all 

8 

Unaure 

5 

Not  IfflDediate 

1 

Too  early  to  tall 

0 

Home 

15 

Basement 

9 

Under  table/bed 

0 

Public  Shelter 

1 

Car 

2 

Other 

37 

9 

13 

3 

2 

1 

0 

0 

2 

0 

2 

3 

3 

11 

6 

0 

0 

8 

1 

0 

1 

8 

10 

1 

0 

6 

8 

8 

6 

4 

10 

1 

3 

1 

2 

0 

1 

0 

0 

2 

6 

6 

5 

0 

0 

1 

I 

0 

0 

5 

11 

223 


Taltphooa  Sur»«y  of   100  Kaddant*  In  tha  Ei^rganey  Planning  Zonal     Suwury  of  Uaulta 
Q^iaatlon ; 


32. 


If  ordarad  Co  avaeuaca,  whara  vould  you 
go? 

Hanover  Mall 

Brldgavater  St.  Coll. 

Taunton  Boap, 

Whcravar  dlracCad 

To  frlanda  of  family 

Juac  away,  no  particular  daatlnatlon 

Don't  know 

Uould  not  avacuata 

Othar 


Plyoouth        Klngaton  Duxbury 

6*  Kaapondanta   14  lUa.   22  Ka«.   Tot«! 


t3.  How  would  you  gat  thataT 


Own  Car 

Other  Car 

Public  Traaaportatlon 

Other 

Uoaura 


34,  Do  you  have  a  car  available T 
(Weekdaya) 


(Weeknlghta) 


(Weakanda) 


-  Yea 

No 

Soaatiaea 

Onaura 

Tea 

Ho 

SoaatlBca 

Unaure 

Yea 

No 
Soaatlaea 

Onaura 


35. 


Uhat  If  no  car  were  avallablaT 


Call Spouac 

Neighbor 

Non-Neighbor 

Walk 

Public  Tranaportation 

Contact  Town  Authority 

Would  not  evacuate 

Other 

Unaure 


6 

2 
1 
7 

IS 

15 

10 

6 

0 

3 
1 

4 
4 


53 

» 
1 
0 

55 

7 
1 
0 

56 

7 
0 
0 


5 

0 
0 

1 

2 
3 
3 

0 
0 

12 
1 
0 
0 
1 


11 
2 
1 
0 

II 
1 
2 
0 

11 
1 
2 
0 

2 
6 

1 
1 
0 
0 

1 

3 

0 


3 

14 

0 

.  2 

0 

1 

7 

15 

5 

22 

3 

21 

2 

15 

1 

7 

1 

1 

18 

79 

0 

4 

0 

1 

4 

S 

0 

5 

21 
0 
1 
0 

21 
0 
1 
0 

21 
0 
1 
0 

0 
f3 
0 
1 
3 
1 
3 
1 
0 


83 

11 
3 
0 

87 

t 
4 
0 

88 

• 
} 
0 

3 

50 
4 
6 
9 
1 
11 
10 
8 


224 


Que»tlon 


Tclcphon*  Survey  of    100  Kctldcnc*   In  Che  Eaergency  Flannlng   Zone:      Sumury  of  Rciult* 

bury 


36.   If  ordered  Co  take  shelter  what 
would  you  do? 


42. 


37.      Do  you  have  a  basement 

(if  not  nentloned  above)? 


Own  basesienc 

Hose-not  baseacnt 

Neighbor  basement 

Public  Shelter 

Evacuate 

Other 

Unsure 

Yes 
No 


38.  Which  provides  greater  protection: 

car  or  basement? 


Car 

Basement 
Unaure 


39.   A  cloud  of  radioactivity  would  be 
visible  during  the  day. 


40.  The  exposure  to  radiation  from 
an  accident  would  be  the  aame  as 
a  chest  x-ray. 


41.  Boston  Edison  made  a  correct 
decision  to  cancel  Pilgrla  II. 


Agree 

Somewhat  agree 

Disagree 

Somewhat  disagree 

Unsure 

Agree 

Somewhat  agree 

Somewhat  disagree 

Unsure 

Disagree 


Agree 

Somewhat  agree 

Somewhat  disagree 

Disagree 

Unsure 

Refused 


rilgrlB  officials  have  done  everything 
possible  for  public  awareness  of 
emergency  procedures. 


Agree 

15 

Somewhat  agree 

18 

Somewhat  disagree 

11 

Disagree 

13 

Unsura 

6 

43.   Desth  is  possible  within  a  few  months 
of  exposure  to  radiation  during  a 
major  Pilgrim  accident. 


Agree 

Somewhat  agree 

Somewhat  diaagree 

Dlaagree 

Unsure 


Plymouth       Kingston  Dux' 
64  Respondents   14  Res.   M 


26 
12 
0 
6 
5 
7 
8 

25 
13 

7 

45 
14 

3 
14 
23 
13 
13 

0 
8 

10 
8 

39 

31 
4 
7 

18 
5 
0 


16 
20 
10 
6 
10 


9 
0 
3 
1 

1 
0 
1 

4 
1 

0 

12 

2 

3 
0 
6 
3 
2 

2 
0 
0 
2 
10 

8 
0 
3 
1 
2 
0 


225 


T«l<Fhe««  Survajr  e(   100  taaldmta  la  th*  Eaargancy  Flanaing  Zona:     Suaaary  of  lU 
QuMtlca 


Fljraouth  Ungaton     Dux 

6*  Haapondanta      U  Itoa.       22 


alta 


lury 


laa.     Tota] 


44.     Veta  ea  quaaclon  3. 


Political  ClaaalficatlonT 


4i.     Marital  StatuaT 


47. 


Imr  rbyateally  41««bl*4  la 
)ieua«heldT 


4(,     At*  V^ 


4ff.     mghMt  Uval  •(  B4«c«tlen1 


Taa 

31 

No 

6 

Didn't  Voca 

19 

Dnaura 

S 

lafuaad 

1 

Conaarvatlva 

20 

Modarata 

24 

Ubaral 

11 

Onaura 

10 

Slaila 

13 

Marrlad 

42 

Dlvorcad  or  Sapacated 

1 

Vldovad 

9 

tafuaad 

0 

Taa 

3 

Rd 

St 

U  -  24 

9 

25-34 

to 

35  -  U 

14 

45  -  54 

5 

55  -  «4 

9 

65* 

17 

Bafuaad 

0 

Orada  tehool 

3 

Se^  Ugh  Mwol 

1 

lith  School  Ovad. 

24 

SoM  Collogo 

17 

Collega  Craduata 

11 

Voac  Craduata  Work 

4 

Hafuaad 

0 

10 


51 

IS 

23 

S 

I 

34 

3a 

14 
IS 

22 
M 

3 
10 

0 

« 

91 

» 
U 
25 

7 
12 
2« 

1 

3 

4 

35 

29 

17 

10 

0 


226 


!\t;.kvii;i\1:R I'UONU  numbur 

r)ATI:       TOWN  


IMi.CRIM  liMliRCHNCY  PLANNING  SURVLY 

"Hello,  my  name  is  .   I'm  calling  from  Opinions  Unlimited, 

.1  ■ Massachusetts  polling  firm.   We're  doing  a  survey  on  emergency  response 

in  your  arcn  and  we've  selected  your  phone  number  at  random, 
I'd  like  to  get  your  opinion  ou  a  tew  things  if  I  may?  (IF  YES,  PROCUED) 

rirst  of  all,  arc  you  a  resident  of  7"  (IF  YES,  PROCEED) 

(same  town  as  above) 

1.  "What  is  your  opinion  of  fire  response  capability  in  your  area 
regarding  response  time  to  emergency  calls?  Would  your  rating 
be  .  .  ."  (RI-.AD  CHOICLS) 

"Very  C.ood"  1 

"Good"  2 

-  "Fair"  3 

"of  Poor"  -4 

(Unsure) (DO  NOT  READ)  5 

2.  "What  is  your  opinion  of  the  quality  of  the  fire  personnel  and 
equipment  in  your  area?   Would  your  rating  be  .  .  ."(READ  CHOICTS) 

"Very  Good"  — 1 

"Good"  2  . 

"Fair"  3 

"of  Poor"  4 

(Unsure)  (DO  NOT  READ)  S 

3.  "What  is  your  opinion  of  ambulance  response  capability  in  your  area 
regarding  response  time  to  emergency  calls?.  Would  your  rating 

be  .  .  ."  (RliAD  CHOICES) 

"Very  Good"  1 

"Good"  2 

"Fair"  3 

"Poor"  --4 

(Unsure)  (00  NOT  READ)  S 

Nkhat  is  your  opinion  of  the  quality  of  ambulance  personnel  and 
""Huipraent  in  your  area?   Would  your  rating  be  .  T  ."  (READ  CHOICES) 

"Very  Good"  1 

"Good"  2 

"Piii  r"  - 3 

"Poor"  -1 

(Unsure)  (1>0  NOT  READ)  b 

"iio  yovi  ever  work  indoors  nt   an  office  or  building  other  than  your 
res  idcnce?" 

Yes  (INCI.UD!:  SO.^IETIMES)  \ 

•■^'o ^^;-  SKIP  TO  Q.  3 

Unsure  * 5/ 


10. 


227 


-2- 
'In  what  town  is  that  office  or  building  located?" 

TokTl  ^ 

Same  as  residence -1 

Not  same  as  residence,  but  job 


in  Plymouth,  Kingston  or  Duxbury  --2 

All  other  towns  ^  ^SKIP  TO  Q.8 

No  job/  Unsure  - 4J 


:> 


"When  you  are  working  indoors  at  that  office  or  building  other  than 
your  residence,  can  you  hear  police,  fire  or  ambulance  sirens  if 
the  windows  and  doors  are  closed?" 

Yes  1 

No  2 

Unsure  - 3 

"Can  you  hear  police,  fire  or  ambulance  sirens  at  your  residence 
when  your  windows  and  doors  are  closed?" 

Yes  1 

No 2 

Unsure  "5 


9   "Are  you  aware  of  any  other  public  emergency  warning  systems?'  (DO  NOT 

READ) 
Pilgrim  Nuclear  Warning 1  CSKIP  TO  Q.  H) 

All  others 2 

No 3 

(ACTUAL  RESPONSE  IF  "OTHER" 


(IF  PILGRIM  WARNING  NOT  MENTIONED,  ASK): 

"Are  you  aware  of  a  warning  siren  in  case  of  an  accident  at  the 

Pilgrim  Nuclear  Power  Plant?" 

Yes 1 

No 2 


■  V  (SKI 


CIP  TO  Q.ll  ) 
Unsure -3 


228 


(II-  AWARE  OP  PILGRIM  SIRUN,  ASK): 
11.  "What  does  the  Pilgrim  siren  mean?"  (DO  NOT  READ) 

Accident 1 

Drill 2 

Other 3 

,      Unsure-  - 4 

(ACTUAL  RESPONSE  IF  "OTHER"__ 


) 


12.  "Have  you  ever  heard  the  Pilgrim  warning  siren  from  your  home  or  job? 

Home 1 

Job 2 

'^° ^  \—     (SKIP  TO  Q.  16) 

Unsure ^^ 

(IF  SIREN  HAS  BEEN  HEARD  AT  EITHER  HOME  OR  JOB,  ASK): 

13.  "Can  you  hear  the  Pilgrim  warning  siren  well  at  (your  home  and/or 
your  job  (DEPENDING  ON  ANSWER  TO  Q.  6)]  when  the  windows  and  doors  are 
closed?" 

Home  Job 

Well 1  Well 5 

Not  well 2  Not  well 6 

Not  at  all 3  Not  at  all 7 

Unsure 4  Unsure 8 

14.  "Do  you  know  the  location  of  the  siren  nearest  to  your  [home 

and/or  job  (AS  APPROPRIATE)]?" 

Home  Job 

Yes 1  Yes 4 

No  2  No 5 

Unsure 3  Unsure 6 

(IF  YES  FOR  HOME  OR  JOB,  ASK): 

15.  "How  far  would  you  estimate  the  siren  is  from  your  [home  and/or 
job  (AS  APPROPRIATE)]?"   (READ  FIRST  THREE  CHOICES) 

"Less  than  1  mile"---i        "Less  than  1  mile"  —  6 

"Between  \    a  mile  "Between  J  a  mile 

and  one  mile" 2        and  one  mile" 7 

"Over  one  mile" 3        "Over  one  mile" 8 

Unsure  (DON'T  READ)--4        Unsure  (DON'T  READ) --9 

Answer  given,  but             Answer  given,  but 
interviewer  doubts            interviewer  doubts 
credibility 5        credibility 10 


^ 


229 


-  4  - 

16.  "What  would  be  your  first  reaction  if  you  heard  the  Pilgrim 
and  a  drill  was  not  scheduled?"   (DO  NOT  READ) 

Evacuate i-1 

Take  shelter -.--2 

Turn  on  radio  or  TV --3 

Turn  on  radio  or  TV  to  an 
Emergency  Broadcast  Station--4 

Ignore- 5 

Unsure 6 

All  other - 7 

(ACTUAL  RESPONSE  IF  "OTHER"       


17.  "Can  you  name  one  of  the  Emergency  Broadcast  Stations  on  radi 
in  your  area?"  (CORRECT  ANSWERS:  WBZ-TV  CHANNEL  4«  WBZ  1030 
WATD  96  FM,  WPLM  1390  AM/99.1  FM) 

Yes - 1 

No 2 

(IF  THEY  ASK  FOR  THE  NAMES,  GIVE  THEM) 

18.  "Have  you  ever  heard  a  Pilgrim  siren  go  off  accidentally, 
when  it  wasn't  supposed  to? 


Yes 1 

'^° ^  ^   (SKIP  TO  Q.  20) 

Unsure 3 


> 


(IF  YES) , 
19.  "How  many  times  have  you  heard  a  Pilgrim  siren  go  off  accident 

Once 1 

Twice - 2 

Over  2 ---3       (ACTUAL  RESPONSE  IF  OVER  2: 


20.  "If  you  heard  the  siren  in  the  future,  how  would  you  determine 
whether  it  was  a  false  alarm?"   (DO  NOT  READ) 

Call  someone 1 

Turn  on  Radio  or  TV 2 

Other 3 

Unsure --4 

(ACTUAL  RESPONSE,  IF  "OTHER" 


230 


-  s  - 

21.  "How  much  do  you  feel  you  know  about  emergency  procedures  in  the 
case  of  a  nuclear  accident  at  Pilgrim?   Do  you  feel  you  know  a 
great  deal;  some,  but  not  a  great  deal;  very  little;  or  nothing 
at  all?" 

A  great  deal 1 

Some --2 

•  •      Not  much,  very  little 3 

Nothing -- 4 

Unsure- 5 

22   "How  4id  you  learn  what  you  do  know  about  emergency  procedures  i 

in  case  of  an  accident  at  Pilgrim?"  (DO  NOT  READ)  j 

TV,  radio,  newspaper- -1 

Official  Emergency  Planning  Brochure 2 

Word  of  mouth 3 

Other - -- 4 

(ACTUAL  RESPONSE  IF  "OTHER"  

) 

23.  "Have  you  ever  received  an  Emergency  Public  Information  Brochure 
in  the  mail?" 

Yes 1 

^° ■ ^  \^    (SKIP  TO  Q."29) 

Unsure ^  ^y 

(IF  "YES",  ASK) : 

24.  "When  did  you  receive  it?  Do  you  remember  what  month?" 

Sept.  '82 1  Fall  '81 S 

Oct.  '82 2  Other  '81 6 

Fall  '82 3  Other- 7 

.Other  '82 4  Unsure 8 

(RESPONSE  FOR  "OTHER" ) 

25.  "Would  you  say  you  read  (PRONOUNCE  "red")  the  brochure..."  (REAP  RESPONSES 

"Completely", 1 

"Partially", - 2 

"or.  Not  at  all". 3    (SKIP  TO  Q.  27  FOR  #3  ONLY) 

26.  "Did  you  find  it  very  helpful,  somewhat  helpful,  or  not  at  all 
helpful?" 

Very 1 

Somewhat 2 

Not  at  all 3 

■  Unsure 4 

27.  "Do  you  have  your  emergency  brochure  available  right  now?" 

Yes 1 

No 2    iSKIP  TO  Q.  29) 


231 


-  c  - 
(11-  Yi-:s), 

28.  "Where  do  you  keep  it?"   (DON'T  PRESS  FOR  AN  ANSWER] 

If  location  given --1 

Unsure  of  location 2 

ASK  EVERYONE 

29.  ''Do  you  have  any  questions  regarding  emergency  planning  in  the 

case  of  a  nuclear  accident  at  Pilgrim  17^'    (IF  YES:  "What 
questions?^ 


30. 


Let's  imagine  for  a  moment  that  the  warning  siren  has  indicated 
that  there  had  been  a  nuclear  accident  at  Pilgrim  I. 

"As  far  as  you  know,  how  dangerous  is  the  situation?  Would  you 
consider  the  situation  to  be  .  .  ."  (READ  CHOICES) 

"Very  dangerous",-  -------1 

"Somewhat  dangerous", 2 

or   "Not  at  all  dangerous",-  -  -  -  -  3 

Unsure - 4| 

No  immediate  danger 5  V   (DO  NOT  READ) 

Too  early  to  tell  -------  6_J 

31   "Where  do  you  believe  is  the  safest  location  for  you  during 

this  situation?"  (if  siren  indicates  an  accident  at  Pilgrim)(DO  NOT  READ) 

Home --------1 

Basement  ------------2 

Under  table  or  bed -3 

Public  shelter  ---------4 

Car 5 

Other -  -  -  6 

(ACTUAL  RESPONSE  IF  "OTHER" 

) 


32.  ''If  you  were  ordered  to  evacuate  because  of  an  accident  at 
Pilgrim  where  would  you  go?"   (DO  NOT  READ) 

Hanover  Mall  -----i 

Bridgewater  State  College   -  -  -  2 

Taunton  State  Hospital  -----  3 

Wherever  directed-  --4 

Other  --- -..-5 

(ACTUAL  RESPONSE  LF  "OTHER" 

) 


34 


36. 


232 


.33.  "How  would  you  get  there?"  (DO  NOT  READ) 

Personal  car  -----------------1 

Other  car  (neighbor,  relative,  friend)  -    -    -    -I 

Public  transportation   -- 3 

Other- - - " 

>    Unsure  ----------  ---S 


(ACTUAL  RESPONSE  IF  "OTHER" 


) 


"Do  you  have  a  car  available  for  your  use?" 

"Weekdays"          "Weeknights"  "and  Weekends" 

Yes 1     Yes 5       Yes 9 

No 2     No 6       No 10 

Sometimes  -  -  3     Sometimes  -  -  7  Sometimes  -  -  11 

Unsure-  -  -  -  4     Unsure-  -  -  -  8  Unsure   -  -  -  12 

35   "What  would  you  do  if  you  were  ordered  to  evacuate  and  you 
had  no  car  available?"   (DO  NOT  READ) 

Phone  spouse 1 

Contact  neighbor  for  a  ride   -  -  -  -  2 

Phone  non-neighbor  for  a  ride   -  -  -  3 

Walk  away ^ 

Walk  to  public  "staging  area" 

for  public  transportation   -  -  -  -  5 

Take  shelter  -  - -  .  -  -  6 

Other 7 

Unsure  ------  

(ACTUAL  RESPONSE  IF  "OTHER" 


8 


) 


"If  you  were  ordered  to  take  shelter  because  of  an  accident  at 
Pilgrim  I,  where  would  you  go?"  (DO  NOT  READ") 

Own  basement  ------------1 

Home  -  other  than  basement  -----  2 

Neighbor's  basement   3 

Public  shelter - * 


Evacuate 


5 


Other -  -  6 


Unsure ----- 

(ACTUAL  RESPONSE  IF  "OTHER" 


7 


233 


.37.   IF  "OWN  BASEMENT"or "CELLAR",  NOT  MENTIONED,  ASK: 
"Does  your  home  have  a  basement?" 
Yes  ------  1 

No 2 

38.  "Which  would  provide  greater  protection  from  radiation?" 

"your  car",  - -1 

"or  your  basement",  -  -  -  -  2 

unsure 3   (DON'T  READ) 

"I'd  like  to  read  you  five  statements.   Please  tell  me  if  you  completely 
agree,  somewhat  agree,  somewhat  disagree  or  completely  disagree  with 
each  statement." 

39.  "If  a  cloud  of  radioactivity  were  released  during  an  accident  at 
Pilgrim,  it  would  be  visible  during  the  day." 

Completely  agree 1 

Somewhat  agree  - -   -    -2 

Somewhat  disagree  -- 3 

Completely  disagree  ------  -4 

Unsure 5 

40.  "The  exposure  to  a  person  outdoors  from  the  radiation  released 
during  a  major  accident  at  Pilgrim  would  be  about  the  same  as 
the  exposure  from  a  chest  X-ray." 

Completely  agree 1 

Somewhat  agree  -----2 

Somewhat  disagree  --------5 

Completely  disagree  4 

Unsure  -----S 

41.  "Boston  Edison  made  the  correct  decision  when  they  cancelled  plans 
to  build  Pilgrim  II,  a  second  nuclear  powered  generating  plant." 

Completely  agree 1 

Somewhat  agree 2 

Somewhat  disagree   --------3 

Completely  disagree 4 

Unsure 5 


234 


42  "The  emergency  officials  at  Pilgrim  I  have  done  everything 
they  could  to  insure  maximum  public  awareness  of  emergency 
procedures  .  " 

Completely  agree  -----  1 

Somewhat  agree  2 

Somewhat  disagree   3 

Completely  disagree   -  4 

Unsure  --  --------5 

43  "The  exposure  to  a  person  outdoors  from  the  radiation  released 
during  a  major  accident  at  Pilgrim  could  cause  death  within 

a  few  months." 

Completely   agree    -.---1 

Somewhat    agree    -----    2 

Somewhat   disagree      ---    3 

Completely   disagree      4 

Unsure    -----    -...--5 

44.   "Did  you  vote  "Yes"  or  "No"  on  Question  3  on  the  November 

ballot?  Question  3  proposed  a  law  that  would  require  that  all 
construction  or  operation  of  new  nuclear  power  plants  or 
radioactive  waste  disposal  facilities  be  subject  to  voter 
approval  in  statewide  elections." 

Yes 1 

No -    -    2 

Didn't  vote  -  -  •  •  -  3 
Unsure   -------4 

Refused  -  -  5 


235 


-     U)    - 

"linally,    i     iu>l    h.i\'c    ,i     feu    questions    foi     c  1 .1  ss  i  f  i  i:;i  t  i  on    injiposcs. 

45.  'Vol  I  t  iciil  ly ,    -li)    you    consitlci     yourself    to    be    i\..."    (RliAD    CHOICES] 
■    ■  "Conservative", 1 

"Modciate"  ,-- Z 

"or  ,    I.  ibe  ral" !^ 

.    (DO    N'O;    RI^.AIl)     Unsuie-  -4 

46.  "Wliat    is    your   marital    status?"     (lUiAP   CHOlCliS) 

"Single", 1 

"Married"  , 2 

"Divorced  or  separated", 3 

"or.  Widowed". --4 

Refused 5 

"How  many  people  including  yourself,  live  in  your  home?" 
(RldCORD  NUMBER ) 

47.  "Are  there  any  physically  disabled  persons  living  in  your  household?" 

Yes--- 1 

No 2 

48.  "In  which  of  the  following  groups  is  your  age?" (READ  CHOICES) 

"  18-24- 1 

*2S-34" 2 

••35.44-. 3 

'45-54'- 4 

■"5  5-64" 5 

"65  and  over 6 

Refused-- 7 

49.  "What  is  the  highest  level  of  education  you  have  achieved?"  (READ  CHOICES) 

"High  school  graduate - 1 

'  Some  college 2 

College  graduate 3 

"Post-graduate  work  or  degree 4 

Refused 5 

"Thank  you  very  much  for  your  assistance.   Good-bye." 

50.  (RECORD  SEX)       FEMALE--- --1     MALE 2 


236 


C  W 

m        *• 

V 

s.    t 


tV. 


■c5,2 

55- 

gS  = 

■    ti    41 


0    w    «  ^ 

CO.  -o 

■   —    w  « 

U     It  H 

•   «-  U 

r  -^  -^  m 

w    k.    C  w 

>-  a-Q  0 


»  3  X 

U  •' 

«  C  -3 

•rf  V  « 

C  w  J£ 

a  X  u 

u  «  a 

o  •  t; 

aC  £  « 


■    G 


lei 


£     - 


s    s    :: 


(ACM 


3  w  w 


,  t 


1^     >t 

o   a 


»3 

O    > 


-    IS-: 


>.   >*   w    ^    • 


■ 
)    •     ■    C 


:  o  « 


o   o  ■« 


u     «      O     « 
"     U     •    fc 

>v-'   e 
^  £   «  k 
c   «   ta  c 

O    >    W  * 


T)     fc-     •     u 

-H      W       fc     2 


1 1 


5::; 


0  9 « 

■    O     M 
**•  »»    ^ 


3   O  —    O 

er—        £  « 
Irt  o   _  0  ^ 

^    I 

■  •» 

■J     (N. 


3-4   •   ■ 
r-t  m 


1 

>•  ftl 

u  « 

«  a 


<5 


&2 


S.3 ; 


237 


hi 


i  -  - 

3    w 

C    V     -3 

-in 

«    C      C 

I  ;  I 


BOO 


.    0     a 


r.- 


U       V 

«.    W     C 

—    « 

C    3    O 

23 

-'i : 

« 

M   «     « 

>      w 

C     _     Q. 

V     u 

-*     II 

•t 

1%^ 

^      3 

—            Q. 

0    e 

«  -o   a. 

0 

ova 

X 

U     «    t7 

j;   o   c 

■o 

•-.         n 

V    c 

•o  x: 

«   « 

u   <o 

4 

O   X    V 

u    ^ 

-:! 

^il 

«   >   u 

a    3 

^      « 

«   e 

m   •    > 

m   e   V 

e  -9 

o 

—    u 

B    a    0 

(«    u   >^ 

-3     M 

J   • 

c  - 

O.-0 

«  — 

u        ei 

o  -O     M 

•    u 

w     W     3 

—   X 

u    & 

n    w 

W     O.    01 

b  «  ^ 

U    £ 

•M    u 

TJ    —   -9 

^S 

T3   — 

V  e   3 

o 

woo 
c  j:   S 

«    • 

V 

■  ^ 

w  w    « 

C     41      • 

2=;i: 

41  j:   u 

*.   g   0 

u    u 

*i   «  - 

M    u   ^ 

t-g-s 

—     3     > 

-•     €»    ^ 

u   c 

>  X  -a 

Ji    V    m 

U  T  r 

<J  X   £■ 

«  -^    > 

1     3     <» 

w 

-sr 

.     .     . 

i.  s 


3   £ 
X     > 


2-a 

U    3 
<  Z 


O     3    k> 

V   C     3 


■i  82 

3   Ul    w 

=    o    I 


—  *  >  • 


•  =  V 

«   £  ■  TS  -q  tl 

«            ■  >  4>  U  u 

*     •  -  m  V 

>^  —    C  tl  3  «  w 

^  ■  b  u  m 

<M    «    >v  «  ••  c  £ 

HH    u  ec  j;  >  M  M 

•  •  **«  TJ 

•  X    >j  •->  «  Q  «f    . 

>>  U    X  •■  j3  u 

<•  JZ  V  u 

>   h   e  u  c  •  « 

S«  a  •  - 

Tj  u  u  a 


ecu    ■    o  Ji  JO    fl    >.j:x 
3  W  U  fl     B    U    u 


;s.: 


Si^ 


•  o   a  M   c 

)    Tl     «|  tS     ■     X'H     W 

:    p    o    «    c  «    3        -4 

I    5    «  —<  ■-*  ■  A* 

•  »<       -<  «    ■  o  o 

tO(aa3uewu 


3i 


•a   o 
c 

a    • 

X  m  <**  m 

«  V    o  • 

C    u  u  -- 

O    C  iH      ■  U 

■   r4  O.  £ 

•»     3  W     ■  ■) 

«  ^  o  a  > 

da  -  b  B 

a    o  ^ 

8**  a    •  o 

a  u    a  X 

j:   >  V 


5   b    g    «    3 
o   a.  >  B. 


o  in    « 


ft 


3    a 

i  M 


mi 

^  -5    a    * 
f       a.  «  • 

"^    w  (A    •>    M 

r  j<  X   a  a 
**   w         3    u 

SS  .''  * 

J  g « •  s^ 

o        w   "  a   - 
"  ■  ^  2  a 


T}   a  w 
«   a 

b   o   a. 


a  -<    3 
c  ^  •-< 

'z  s 

a   o  -n 
a.  c 

>    C    a 


•2& 

k.     >     W 

33i 


-      -O 

O     C   —    - 

£  -a  u  . 


a 

b   ■-« 
O    U 

C  X 


9.   <_ 


3  V 


•r   c 

«    e    3   « 

»   S  c  " 


06  a  *■  >  • 

A-  a  X  u 

W1  •«                 U  -4 

X  ■*<    O    »  O 


>.  o  a 

'4    w  X    u 

c  o 

O    «  £ 

X  u  -* 

a  w  -4 

a    >>'5   o 


C      U 


■s-i 


c£ 


It 

U     X      It      N 

K  a  o  '^ 
53  '   2 

^S  J' 

:  ••ss 

B    •    3    M 

•    u   «    ^ 

<    «  X  >t^ 
^    H   *l    o 


>s  e  u 
--•  a  a 
-•  X    a. 


a   b  X 


u    c    u 

2LS  £ 

a    h     M 
a    IL  jj 

•w  -c   a 

2  t^ 

o  -a   ■ 

"Si 


X    &   I 


t  1 


•a  X 


b     C 


238 


W   X  ■W    — 

V  m  "BO 

«         •  "  *: 

«    O  WW  ■    ,^   " 

CD.       «  e        •   o  5 

«     ■  3    4  "*     ^    S 

a.  bi        U  "o.      —  «   h* 

a    «i         «  i<  «i  e   u 

u  X             •  >  3 

-<  «        >,  •  em 

C-*  *  «  • 

3     «  3  O    X     « 

o  ^       e  c      •£  w  B 

jt    m        -r*  u         c 

■  ■  I  *-  -< 

c  «       ».  o 

«  O  Ok.  0         "^ 

«   W         —    M  tl    O 

Q  W    w   -■     •     «     C 

£.       •  «     M       fl  ■      «l 

A.   •  X  e  w 

C  W     >.    U     4^     « 

V  «         o  u  X        -*  ^ 
x<hi       wcu'oa.'.* 

a  «>  M  c   a  X   > 

o  aw—        w 

■-   -*  p    41          u    D    c 

M  G   I    ■   ^    Q    o 

■  >  <«>I«oi<i 

u  «   2   c  a*   « 

•«    •  fH  c    •  B. 

vt     M  >     Q  44    X      O 

U  -*•!-« 

«  X  U    u   X    ^ 

•M    w  C    **    £  " 

*.  w    V  0.0 

-<>  X>».-^>.W 

■  fc.    4P     O    "    „ 

c  **  3  -'  "S 

-«•      xxoii-^Tj 

«J    u  «   -«     *     U     3 

U     C  ^  u     >     ■   -I 

U    u  w  -4     3  C 

U  ■■     W  u     »<     4>   *4 

.0«C«C«3X 
uwouo>*<wa 
—    —    C  —    •  -* 

«  w    O   w  V    4J 

X'*'4uak.'-««> 
4>  e   d       3  o  X       « 

U     C     U   «<     «     ■     3 
w    ■*     O     «r    «  -H     «l 

X  "  —  -   >   ■  • 

«    «    «•   «    O    «  " 

V  a  X  -M  u    •         00 

«     .^  h       «t    IH       C 

■OXJ>>«0'-<0--' 

U^O^,-^     CX     *IT3 
•     C     OXQ.*     •■* 
u«<wu  b>B>. 

C  «    «     u  3     u 

o   e   V  f  -        ».  c  —    • 

U     O   X  >,'-     o  ^     >> 

U«        X-         j-cy-- 
—   30       Cex^**  — 

C/l«  a««33«« 

M>>.X«.iCUXO' 

2  -'tlVVUW  V 

c->££^j:x    CX 

W      ««,-.,-.    ^    rt 

0  •*-  —  1^  f  -»  ''^ 


u 

C     Q. 

a 

Q.   O 

X   «  o 


O     V 

a.  w 


Ji  : 


W     4     C 

3     •   -<  * 


::^  e 


--  tt.    3  V    -r* 

-■  —     «  -Ot  >     K 

■-  «)     C  C            « 

3  X  -^  a  U>    ■ 


O                                 T)|                      ■  W    O    « 

«  -O              ••           C  l«  'X  X          -v 

*-•       «»«i«|       «**>,J  a*www>« 

««iCW«                ^cu  «■           «^ 

-^    7    o      «         w-aaw.  h>ct)>v< 

t3--           Monw  -*c«> 

«        w      cacuaua  >.w«440 

b.-4«      bx-^u         ««  w«         ah. 

3a3        «l           B-0>»'  CWCXQ 

■ocu     y>y       co-oti  ■«>'aa> 

«oac44X«         CX  a        -^         « 


•  u  ■j*-io<4-ox>>        im   u   m   o   * 
I  -^.oox         a-D«a3 

;c  —   y               Ecflcoxuxa 

•-•  ea«a93o         n   c   ai   n  u   V 

I  -"fc-kjac         v         3        >^^ 

:-ou  Co         aB-        civ^w 

n  ax^«^v4j        xwu^r-i 

•  aw-4ecu-  -_- 


12 


•4    «  *^  X 
«    c         S 

W   -O    (M     0     O    tA   r 


-■   y 

C     q 

5  J 


C  4)  -4 

>■    «  >  u 

y    w  i«  o 

c  -•  X  c 

afi  >,  w 

b    «i  o  u 

Sy  X  CI 

C  •^  u 


O   X  b  B 

o  a  c 

c    w.  u  a 

o   a  X  y 


a  3  X  h.  c 

u  o  •>  o 

-4  ^4  U  X  -4 

•4.  U  O  4J  4J 

—  a  c  c  a 

W  3)  C  O 

o  a  o  -« 

z  a  u  c  <*. 


S£ 

C 

-O     41   —   O 

=   >.o 

??■/ 

>.    3   ^ 

^iiS 

a  U  *•  r. 

IS 


<   «    ■ 


e   c   a  o 


8.5 

>s  y  u  X 


a  1 

,    O     44     u 

v\  a    fl 


a 

7S 

jt  & 

« 

u  a 

>      4J 

3   u 

X 

b      •  X 

way 

•i^ 

—  r*    0 

Si 

J<  o 
,  y  X 
-4  3  a 
X    b 


"   y   a 

«i   a   c    a   b 

kJ    >    0    o  -^ 

4»  a  '.4  c   « 

X        a   0  X 

>   «  ^        w 

X   >    ■ 

W          O    O    w 

3  o  k>  X   a 

i-*",  . 

a   41  u  w  a   c 

u  m   o   >   0 

5«-§-t:2 

■   a         «   b    a 

-J    »  -o  T»   a    c 

s a  • '  ss 

c    c   0    a    a    « 

=3    -4     44    JJ    X    -O 

a   • 

>•  « 

a  a  u 

■H  >  a  o 

w 

c   •   e 

3 

a   0         0        -*  1^ 

X 

b    c        -4   a         a 

a         O  "   fc*  ■^  X 
41  44  2   a   a   c   > 

a  : 

>s  3        u        a 

■H    X 

X     .  -4   a         > 

-*   w 

—           T)    1-     c    *•     0 

iS 

a     -  .-1  ^  a  *.    c 

u  CO  «   w  b   a  j< 

u 

y   c  X   0  -4  44 

a  X 

>  -4        z   a    a  M 

X      44 

a  u   b 

■  5  S  .:  •  S  S 

•J 

(>   a  X  X   o  -^ 
a    y  ^  l-  ^  — 1 


»    <*4      c 

.    o    -    g 


8^: 

>^  C    I 


^s, 


O    W  X 

V  a 
a  u  j< 
>  c  b 
a    o    P 

X  u  5 

<-i   w   u 
•^3    0 


239 


3    M  £ 

c  ^   o 


u  a  e 

e  £.  « 

q  a 

•1!  >.  >. 


«       5 


-■s  e 

• 

«   u   ■ 

«    a    « 

c 

3          ^ 

0 

X 

« 

HI 

1 

a  e 

^ 

—  « 

ft 

C 

(s    n    CO 

-H       O. 

c 

w    u    c 

c 

o 

a   « 

3  -c    <o 

c 

■S-SE 

? 

0     3 

o 

1     s 


i    s 


it 


a  J! 

S 

£    >^ 

M 

C 

e 

>>  *l 

00 

XI 

o 

S^ 

"O 

u    o 

4 

41 

£  X 

V   -* 

«  c 

3     « 

•1 

.5 

5   5 


3    O 


i     X 


X     ft)   ^     M    Z 


-i  = 

C      19 


a.  -o  . 
V    c 

U      1    • 

a.  £ 


o   a   >  t) 


4  S 

a  £ 


t  -r  w-i  a  £ 


SI 


«    c  <  -. 

—  or  « 

3     u  J< 

^   Jt  •  u 

~   o  c  »  o 

O  O  00    ^ 

u  e  '    V 

O    V  -d  ■£     C 

-   <?  ^  -T     C 

-i  f^  <  r*    < 


«  ^      c   a 


3   -O 

«>afl>.«c--a 

O  -^    C                Z  tM     «    « 

cxa     -o        >*«i.u 

o ,  ¥ ' !  -  . :  2  J! 

3nu-.j=«6^a-* 

c    « 
a    « 

3     w 


6    .o  - 

X     C   O  h 

U     O    -f  « 

3    -»  •— 


1"^. 


c  —  c  (M  i.  —  a 

o  "^  o  o  a  ^  h 

-  -)   *J    1  u 

—  «  .  o  • 

>  -•  a*  U  Q  i, 

c*.  <r.  X  •«  X  O  r 


240 


4     « 

j:  — 


is 


m  M 


o  ^ 


55 


£5> 


J1 


1 
J  i  ^  &      *j 

e>  f  K  u  •  7 

Tllli 


s 
1; 


1 


<s 


MM  ••         • 

ki  e  H  »•  — 


9  B    o 

«  w  Ji 

— I  e  o 

w  3    O 

3  I-  «. 


u   b.  ■  « 
•  w  >-<  . 


Si 


II 


Z  '-'       a.  <  «  < 


»«    B  O  -       - 

I     i  Ik.     3  y   U     I     • 


e  w  <«  '• 

1 3-; 

o  u  • 


X  . 

, 

•  r^i 

1^1 

?£ 

M 

C    •    w  -«    A 

1^ 

:> 

-"so. 
13  £    a  (A    I 


li 


fc      •>«  b  &  e  e  o 


i« 


M 


i2: 


wox>«*-**> 


O    II 


■  w  r      ■ 

3  •  < 

C  *^ 
IW  ■Mil 

Im    —      •    '^    J 


is 


5    .5 

•   9 

•o  «  ^ 

3    «   -" 
%^     - 


3  tl 


&  • 


i    :I 

3  U     « 

i     Si! 


m  m 

«  • 

3  '-•  X 

«  fl    c 


it     !. 


Mi       e 

^  X         W 


>  i  I   • 

AW  w 


>    u 

•   O  «•   ' 

«   w  X    • 


fl   w 
0   «   c 

W     &    0 


-i 


5u    o  o  « 

U    o    X   —  4 
•  US' 

X  O    •^  <«  ta 

5  •^  wt  »  C 


241 


a.   I 


:  a.  a. 
'  ■  m 
1  e  o 


u    V   X 
I     >    o 


U     3 
a.  a 


;  s 


>  «  « 


41  tn  n 

c  k.  -• 

II  '1  « 

o  S  o 


£     & 


s    r 


i>    i 


C     k.     M   X 

O     41    -r<     3   O 

X  at    «    u  : 


O     ■• 


X     C  V  b 

^  Ck  <• 

«(  V  V 

O   w  -o  >. 

c   — 

O  >s*. 

^  ~>  o 

•    3  J3 

at  o  •«  u 

w  X  ^  e 

c    «  o  -• 

O  w  u 

■a  o. 

mo:  •« 
c    w 

ai    u  —>  k. 

—  11  X 

n    u  &  t^ 


■«   o 


W    k.   —     c 


I- 


^2- 

■O     3 


C    w     O 

3;i 


242 


i  3 


:  1, 

—   «   c 

MrH      4 

O    »■ 

£■»£ 

U  -9  £ 

-?^. 

0   -O  —  — 

•   (1  -  ■- 

—  u  V 

O    ••  4J   ^   -o 

90  C           'V 

>.   O  V     O    w 

w   ^  i     -     « 

-  O  "           3 
^    -<  «    u     U 

^    a  u    c    > 

<     h  w     3     V 

■o  -•  «■ 

il     BO  .^ 

C     O  C 

«4    -^  « 

4    O  -Q 


J'S 


^ 

0 

« 

£ 

n 

^l" 

J- 

3 

a 

V 

TJ 

tt 

e 

> 

> 

i 

X 

a. 

■o 

« 

« 

? 

^ 

o 

> 

n 

c 

e 

c 

« 

trt 

3 

i    s 


1   ? 


M     U      I 

■   u 

W     > 


^1 


«  -^  • 
■^  a 

m  & 


li 


P  M  • 

o  «  • 

>«  •  fl  •  • 

«     V  1  » 

M  a  «  I  J< 

k>  u  ki 

3  h  e  ■  D 

■    0  o  •  S 

b  b  w 

2   1  £  a  e 


w  AX 


-      i. 


WWW 


3    c         " 
O    4   "Q 


O    O    It    ' 
a  13 


is     £ 


2  il 

■    C 


—       o       — 


w  O     ■ 

O  « 

7s    S 


.   TJ     *•  (rt 


■Si  . 

hi 


a  a 


u    V   »• 

U     C     V 


O    O  -Q    u    « 

w        o   a.x 


•  •JAM 
■     •     9     • 

•  3  W 


a 


is 


v>    w    I 


If 

3 


243 


NO  EXIT 


The  MASSPIRG  Survey  of 
Pilgrim  Evacuation  Planning 


MASSPIRG 
September  1987 


244 


NO   EXIT 


THE  MASSPIRG  SURVEY  OF  PILGRIM  EVACUATION  PLANNING 


Authors 

Josh  Kratka 
Rachel  Shimshak 


Research  and  Technical  Experts 

David  Nemtzow 
Alan  Nogee 


Survey  Director 
Maria  Mobil ia 


MASSPIRG 

29  Temple  Place 

Boston.  MA  02111 

(617)292-4800 

September  1987 


245 


ACKNOWLEDGMENT 

Special  thanks  are  owed  to  David  Nemtzow  of  the  Kennedy  School  of 
Government  who  supervised  the  survey  and  conducted  the  statistical  analysis, 
to  Maria  Mobilia  for  coordinating  the  survey  callers,  and  to  the  many  MASSPIRG 
researchers  who  spent  hours  on  the  phone  compiling  the  necessary  data  for  this 
report.   Thanks  also  to  Amy  Kelley  for  the  cover  design.  Sue  Haynie  for 
production  of  this  report,  and  Mike  Ernst  of  the  State  Legislature's  Energy 
Committee  for  reviewing  an  earlier  draft  of  this  document. 


246 


TABLE  OF  CONTENTS 

EXECUTIVE  SUMMARY  1 

I.  INTRODUCTION:  THE  LESSONS  OF  CHERNOBYL  3 

II.  SURVEY  RESULTS:   PILGRIM  DISASTER  PLANS  ARE  STILL  A  DISASTER 

A.  Pilgrim-Area  Residents  Are  Inadequately  Informed 

About  Emergency  Planning  7 

B.  Residents  Will  Not  Follow  the  Emergency  Plans  10 

C.  The  Emergency  Plans  Do  Not  Address  the  Needs  of 

Many  Population  Groups 

1.  Families  With  Children 12 

2.  The  Elderly  13 

3.  Newer  Residents  14 

D.  The  Flaws  Revealed  by  the  Survey  Render  the  Emergency 

Plans  Unworkable 

1.  Present  Warning  Methods  Are  Unlikely  to  Alert 

Res  ident  s  Quickly  15 

2.  Phone  Lines  Are  Likely  To  Be  Tied  Up  During  an 

Erne  r gency  15 

3.  Orderly  Evacuation  is  Unlikely  to  Occur  16 

E.  Most  Residents  Surveyed  Want  Pilgrim  to  Remain  Shut  Down  ..18 

III.  DETAILED  SUMMARY  OF  QUESTIONS  AND  RESPONSES 

A.  Methodology  19 

B.  The  Survey  20 

IV.  RECOMMENDATIONS  33 


247 


EXECUTIVE  SUMMARY 

In  light  of  the  General  Accounting  Office's  finding  that  no  federal  agency 
assesses  public  knowledge  of  radiological  emergency  procedures.  MASSPIRG 
surveyed  363  residents  of  the  Pilgrim  nuclear  power  plant's  Emergency  Planning 
Zone  (EPZ)  to  determine  what  people  know  about  the  official  emergency  plans  and 
whether  they  would  follow  those  plans  in  case  of  an  accident  at  Pilgrim. 

The  key  findings  of  this  survey  show  that  residents  are  even  less 
informed  about  Pilgrim  emergency  plans  than  they  were  at  the  time  of 
MASSPIRG's  last  such  survey,  conducted  in  1983.  Moreover,  they  would  refuse  to 
follow  official  instructions  in  the  event  of  an  emergency. 

1.  Residents  have  only  a  limited  knowledge  of  emergency  plans  for  their 
communities.   Only  56%  of  those  surveyed  said  they  had  received  the  Emergency 
Public  Information  booklet  from  Boston  Edison,  the  operator  of  the  plant, 
compared  with  67%  who  remembered  receiving  the  booklet  in  1983.   Moreover,  only 
23%  of  those  surveyed  said  they  had  actually  read  the  booklet  completely, 
compared  to  38%  in  1983.   Those  living  in  the  EPZ  for  three  years  or  less  have 
been  particularly  ill-informed:   47%  had  not  received  a  copy  of  the  booklet. 

2.  Many  residents  would  not  follow  the  emergency  plans  in  case  of  a 
serious  problem  at  Pilgrim; 

*  the  most  common  response  to  an  accident  at  Pilgrim  (27%  of  those 
polled)  would  be  immediate  evacuation  —  a  direct  contradiction  of  instructions 
contained  in  the  emergency  information  booklet: 

*  only  19%  of  those  questioned  said  they  would  go  to  one  of  the 
designated  reception  centers  in  case  of  an  evacuation,  and  two-thirds  of  these 
few  who  would  follow  the  emergency  plans  would  go  to  the  Hanover  Mall,  which  is 
no  longer  an  official  reception  center; 


248 


*  of  the  37%  surveyed  who  have  school-age  children,  nearly  half  (48%) 
said  that  they  would  try  to  pick  up  their  children  from  school  in  the  event  of 
an  emergency  —  precisely  what  the  emergency  booklet  instructs  them  not  to  do; 
just  9%  of  parents  said  they  would  follow  the  instructions  to  meet  their 
children  outside  the  danger  zone. 

3.  The  emergency  plans  do  not  adequately  take  into  account  the  special 
needs  of  children  and  the  elderly. 

4.  Seventy-nine  percent  of  the  respondents  felt  that  Pilgrim  should 
remain  shut  down  if  management  and  safety  problems  persist. 

5.  When  asked  whom  they  would  trust  for  information  in  the  event  of  an 
accident.  3H  of  respondents  said  they  would  have  no  confidence  in  Boston 
Ediaon.  easily  the  worst  score  aiiong  the  people  and  groups  mentioned. 

Since  the  accident  at  Three  Mile  Island,  the  Nuclear  Regulatory  Connission 
has  required  ccoaunities  within  a  10-nile  radius  of  a  plant  to  have  workable 
evacuation  plans.   In  July  1987,  the  Federal  Emergency  Management  Agency 
(FEMA)  found  the  Pilgrim  plans  inadequate  to  protect  public  health  and  safety 
and  withdrew  its  interim  approval  of  them.  The  findings  in  HASSPIRG'a  report 
clearly  show  that,  given  the  current  level  of  information,  the  Pilgrim 
emergency  plans  would  not  adequately  protect  the  public  even  if  the 
deficiencies  identified  by  FEMA  were  corrected. 

In  light  of  these  results  and  aerious  management  and  safety  problems  at 
Pilgrim,  MASSPIR6  recommends  that  the  Pilgrim  plant  should  not  reopen  unless  it 
is  determined  that: 

(1)  workable  plans  can  be  developed; 

(2)  such  plans  have  been  effectively  disseminated  and  implemented,  and 

(3)  outstanding  management,  safety,  and  economic  questions  have  been 
resolved. 


249 


I.   INTRODUCTION:   THE  LESSONS  OF  CHER>10BYL 
7  'e  Chemobj'l  disaster  it  April  of  1986  provided  a  sobering  glimpse  of 
'  ' ''^.  Lu -:.le  devastation  that  could  result  from  a  nuclear  power  plant 
■  ■ -idci'-   The  Soviet  government  was  forced  to  evacuate  135,000  people  living 
Jichln  an  18.6-mile  radius  around  i-he  plant.   Thirty-one  people  have  already 
aieu  a^  a  direct  result  of  the  accident,  and  24,000  more  are  expected  to  die  of 
a.-<=r  ca"sed  by  rac'iation  exposure.   Fallout  from  the  plant  contaminated  crops 
.  .;C  dairy  products  across  Eastern  Europe  and  vas  detected  as  far  away  as  the 
vt.ct  coa-.t  of  the  United  States.   On  June  16,  1987,  the  Boston  Globe  quoted 
:,(.:istantin  Fursov,  a  So^ritit  olf  ioi.-.^ ,  to  the  tite<-L  that  27  cities  and  villages 
within  an  13-mile  radius  of  the  plant  are  "too  contaminated  for  people  to  live 
in  for  the  foreseeable  future."   The  world  learned  —  the  hard  way —  that 
i-oi'-'erts  can  and  will  happen,  with  devastating  consequences. 

The  Chernobyl  accident  halped  fuel  the  debate  in  the  United  States  about 
n  -li.ar  pcwer  in  genaral,  and  in  Massachusetts  over  safety  and  evacuation 
'  L.OE  at  the  troubled  Pilgrim  nuclear  power  plant. 

'licensed  in  1972,  the  Pilgrim  reactor  in  Plymouth,  Massachusetts,  has  led 
-;  -crturtd  life.   Initially,  the  plant  was  loaded  with  "bad"  fuel  which 
substantially  increased  the  radioactivity  in  the  plant.   As  a  result  of  this 
•  J  other  problems.  Pilgrim  has  only  produced  about  half  as  much  energy  as  it 
•.o'lld  if  it  had  been  working  continuously  at  full  power  over  its  life  today. 
In  1982,  Boston  Edison,  the  owner  and  operator  of  the  Pilgrim  plant, 
reived  the  largest  fine  levied  against  a  power  plant  at  th?t  time,  for  two 

•sty  violations  and  a  "material  false  statement."  The  Nuclear  Regulatory 
commission  (NRC)  was  so  ccncemed  abo-it  conditions  at  Pilgrim  that  it  ordered 
■:..'    y^iiir.y   to  conduct  a  "management  overhaul"  in  that  same  year. 


250 


Despite  promises  to  improve  its  operations  in  1982,  the  plant  continued 
to  receive  poor  grades  from  the  NRC  in  its  periodic  management  performance 
reports. 

RBCENT  BISTORT 

In  early  April  of  1986,  the  reactor  experienced  two  "unexplainable 
automatic  shutdowns"  or  "scrams,"  touching  off  17  months  of  harsh  criticism 
from  the  NRC,  elected  officials  and  citizen  groups  across  the  state  about 
Pilgrim's  problems.   Ir  a  May  1986  Congressional  hearing,  the  NRC  labeled 
Pilgrim  one  of  the  "worst  managed  and  least  saie  plants  in  the  country."  The 
morning  papers  began  to  carry  headlines  such  as  "Pilgrim  Missed  Another 
Deadline  for  Safety  Tests.  "Pilgrim  Workers'  Radiation  Exposure  Among  Nation's 
Highest,"  and  "New  Doubts  Voiced  on  Future  of  Pilgrim." 

The  Department  of  Public  Utilities  issued  a  scathing  indictment  of  Boston 
Edison  in  June  of  that  year  accusing  the  company's  management  of  being 
"paralysed"  to  the  point  where  officials  are  no  longer  able  to  properly  run  the 
plant.   The  300-page  report  stated  that  if  Edison  continued  along  its  current 
path,  "it  will  jeopardize  the  health  and  safety  of  its  customers  and  the 
economy  of  the  region." 

After  documenting  years  of  management,  structural,  and  evacuation  problems 
at  the  plant,  MASSPIRG  submitted  a  50-page  petition  to  the  NRC  asking  the 
Commission  to  suspend  Pilgrim's  license  until  all  of  the  safety  issues  were 
resolved,  and  to  hold  a  comprehensive  public  hearing  to  discuss  each  problem. 
Joining  MASSPIRG  in  filing  the  "Show  Cause"  petition  were  over  50  state 
legislators,  a  dozen  citizen  groups,  and  statewide  candidates  for  attorney 
general  and  lieutenant  governor.   The  theme  of  the  petition  was  that  taken 
individually,  the  problems  described  are  serious.   In  the  aggregate,  they 
thoroughly  compromise  the  reliability  of  the  most  important  safety  systems 


251 


*:hp  plant  .md  destroy  the  fundamental  principle  of  defense-in-depth 
•^por,r,e<i  by  the  NRC. 

Some  of  the  emergency  planning  deficiencies  noted  in  the  petition  were: 

1}  Lack  of  advance  information  about  emergencies  for  residents, 

'-anintnts,  and  tourists; 

2)  Lack  oi  adequate  medical  facilities  to  treat  contaminated  individuals 
i.n  the  event  of  an  emergency; 

3)  Lack  of  emergency  plans  for  Cape  Cod,  located  11  miles  from  the 
P-lgriiB  plant,  and  other  communities  just  outside  the  official  evacuation 
;■ 'anning  zone; 

4)  A  lack  of  attention  tc  .smergency  planning  by  federal,  state  and  local 
'jovernment  agencies; 

5)  Lack  oI  adequate  capability  and  planning  for  notification  during  an 
accident,  and 

6)  Lack  of  adequate  plan^  for  evacuating  the  physically  disabled,  nursing 
home  residents,  school  children,  hospital  patients,  campers,  and  inmates  of 
correctional  facilities. 

Secretary  of  Public  Safety  Charles  Barry  underscored  the  problem  areas 

roted  in  the  petition  in  a  100-pagc  report  to  the  Federal  Emergency  Management 

Agency  (FEMA)  in  December  of  198d.   At  a  December  State  House  hearing. 

Governor  Dukakis  submitted  that  report  and  stated  that  Pilgrim  should  remain 

closed  until  ai' 1  previously  identified  management,  reactor  safety  and 

emergency  planning  concerns  have  been  adequately  addressed. 

In  light  of  this  criticism,  Edison  should  have  been  well  on  its  way  toward 

cleaning  up  its  management  and  safety  problems  by  1987.   But  the  most  recent 

:'''.C  pe-=crmance  repor"  Clo.  50-293/86-99.  dated  April  8,  1987)  concludes  that 

tnere  are  "significant  recurring  program  weaknesses  ...  and  that  the  rate  of 

change  was  slow  during  most  of  the  assessment  period."   In  five  of  the  twelve 

functional  areas  graded  by  the  NRC,  Pilgrim  received  the  lowest  possible  score. 

Thes^-  developTients  and  other;:  led  a  special  legislative  conunittee  on  Pilgrim  to 

issue  yet  another  report  critical  of  the  plant  and  its  operations  in  July  1987. 


252 


E7ACDATI0N  nj^NNING  TODAY 

After  the  accident  at  Three  Mile  Island  in  1979,  the  NRC  required  nuclear 
plants  to  have  workable  emergency  evacuation  plans  for  the  population  living 
within  a  10-mile  radius  around  the  plant.   In  the  case  of  the  Pilgrim  plant, 
Boston  Edison's  record  of  safety  violations  and  management  problems  makes  the 
existence  of  feasible  evacuation  plans  that  much  more  critical. 

After  17  months  of  shutdown,   however,  there  is  still  no  progress  on  the 
workability  of  emergency  plans  for  the  Pilgrim  area.   On  August  6,  1987,  FEMA 
released  a  report,  entitled  "Self-Initiated  Review  and  Interim  Finding,"  which 
further  criticized  Pilgrim's  emergency  plans  and  found  them  "inadequate  to 
protect  the  health  and  safety  of  the  public  in  the  event  of  an  accident,"  The 
five  reasons  highlighted  in  the  FEMA  finding  were: 

*  Lack  of  evacuation  plans  for  public  and  private  schools  and  day-care 
centers; 

*  Lack  of  a  reception  center  for  people  evacuating  to  the  north: 

*  Lack  of  identifiable  public  shelters  for  the  beach  population; 

*  Inadequate  planning  for  the  evacuation  of  the  special  needs  and 
transport  dependent  population; 

*  Overall  lack  of  progress  in  planning  and  apparent  diminution  in 
emergency  preparedness. 

Many  of  the  inadequacies  cited  in  the  FEMA  report  had  been  raised  years 
before  by  MASSPIRG  in  its  1977  and  1983  reports  on  evacuation  planning, 
entitled  "blueprint  for  Chaos"  I  &  II,  and  most  recently  in  the  July  1986  "Show 
Cause"  petition.   Because  several  conditions  which  affect  emergency  planning 
have  worsened  in  the  past  few  years,  MASSPIRG  decided  to  follow  up  its  earlier 
reports  with  this  study. 

The  1977  and  '83  reports  generally  looked  at  the  adequacy  of  emergency 
plans  themselves,  as  did  the  recent  FEMA  study.   This  report  approaches  the 


253 


5=mergC;ncy  plan;  rrott  a  diilcrexii;  o  I'^ie  ■-  it  ijoks  mc  it  the  plans  themselves 
but  at  the  people  who  w3.ll  be  ask?d  tc  follou  t'n.;rr..   Such  information  is 
crucial  to  assessing  the  feasibility  of  the  plans,  particularly  in  light  of  the 
General  Accounting  Office's  finding  that  "no  federal  agency  assesses  public 
knowledge  of  radiological  emergency  procedures."   (GAO  Report  to  Hon.  Edward 
J.  Markey,  House  of  Representativc^i,  "Nuclear  Regulation:   Public  Knowledge  of 
Radiological  Emergency  Procedures,"  June  1987,  p.  1.) 

MASSPIRG  surveyed  363  people  vho  live  in  the  Pilgrisn  Emergency  Planning 
Zone  (EPZ)  to  answer  these  basic  quest-.onti; 

(1)  Are  EPZ  residents  kntiwiedgeaL'^e  ;ibout  the  emergency  plans? 

(2)  Will  residents  be  wii Ling  and  able  to  follow  tiiese  plans? 

(3)  What  do  residents  think  about  emergency  planning  and  the  Pilgrim 
nuclear  plant  in  general? 

The  survey  methodology,  along  with  the  orecise  questions  and  answers  are 

described  in  Section  III. 

I I .   SURVEY  RESULTS:   PILGRIM  DISASTER  FLANS  ARE  STILL  A  DISASTER 

A.   PILGRIM-AREA  RESIDENTS  ARE  INADEQUATELY  INFORMED  ABOUT  EMERGENCY  PLANNING 
The  first  major  conclusion  to  be  drawn  f'-om  out  survey  is  that  the 
residents  of  Plymouth,  Kingston,  Duxbury  and  Carver  have,  on  the  whole,  a  very 
limited  knowledge  of  the  emergency  plans  for  their  communities,  and  that  they 
are  even  less  well  informed  now  than  they  were  four  years  ago.   This  conclusion 
is  apparent  from  the  responses  to  virtually  every  survev  question  which  tested 
familiarity  with  the  basics  of  the  emergency  plans,  from  warning  methods  to 
evacuation  procedures. 

A  large  share  of  the  blame  for  this  situation  must  be  attributed  to  Boston 
E'iison's  failure  to  educate  the  public.   The  company  has  relied  almost  solely 
on  its  booklet,  "Emergency  Public  Information:   What  To  Do  In  Case  of  an 


254 


Emergency  at  Pilgrim  Nuclear  Power  Station,"  and  claims  to  have  distributed 
copies  of  it  to  all  residents  ot  the  EPZ  in  November  1986.   There  have 
obviously  been  distribution  problems:   just  over  half  (56%)  of  those  surveyed 
said  they  had  received  the  booklet  (see  Question  9).   This  figure  represents  a 
noticeable  step  backwards  from  1983.  the  last  time  MASSPIRG  surveyed  EPZ 
residents.   In  1983,  67%  of  those  surveyed  said  they  had  received  a  copy  of  the 
emergency  planning  booklet. 

An  added  problem  with  relying  heavily  on  written  information  is  that  not 
everyone  who  gets  it  reads  it.   Nearly  two-thirds  (62%)  of  those  who  received 
the  booklet  admitted  to  us  that  they  had  read  it  only  partially  or  had  not  read 
it  at  all  (see  Table  1.  below).   Thus,  while  56%  of  the  total  sample  remembered 
receiving  the  emergency  information  booklet  (Q.  9),  a  mere  23%  had  .read  it  all 
the  way  through.   In  1983,  38%  of  those  surveyed  by  MASSPIRG  said  they  had  read 
the  booklet  completely.   The  lack  of  public  education  suggested  by  these 
numbers  is  verified  by  the  answers  to  several  other  questions. 

TABLE  1 

SURVEY  RESPONDENTS  WHO  HAD  READ  THE  EMERGENCY  PLANNING  BOOKLET  ... 

%  of  Those  Who         %  of  Total 
Number Received  Booklet Responses 

COMPLETELY  82  33  23 

PARTIALLY  109  4 A  30 

NOT  AT  ALL/NEVER      149  18  41 

RECEIVED  BOOKLET 

DON'T  KNOW/REFUSED     23  5  6 

(Based  on  responses  to  Questions  9  and  10) 

While  most  respondents  knew  that  warning  sirens  would  be  used  to  signal  an 
accident  at  Pilgrim,  very  few  knew  that  they  should  also  tune  in  to  local 


255 


television  and  radio  stations  to  receive  more  complete  information  and 
instructions  on  what  to  do  (Q.  2.  12).   This  becomes  more  significant  in  light 
of  the  fact  that  the  respondents'  most  common  reaction  to  learning  of  an 
accident  at  Pilgrim  would  be  to  evacuate  immediately,  contradicting  the  express 
directions  in  the  emergency  information  booklet  (Q.  11).   There  is  a  great 
danger,  therefore,  that  people  will  hear  the  siren  and  flee  without  waiting  to 
receive  important  information  and  instructions. 

Even  when  evacuation  is  the  right  action  to  take,  few  of  those  we  surveyed 
would  know  where  to  go.   Less  than  one  in  five  named  one  of  the  three 
evacuation  centers  specified  in  the  booklet,  and  of  those  few  who  knew  where  to 
go.  a  third  did  not  know  the  proper  route  to  tfke  (Q.  14,  15).   The  problem  is 
even  more  acute  for  parents  of  school-age  children.   Nearly  70%  of  the  parents 
surveyed  would  not  know  where  to  find  their  children  if  an  evacuation 
occurred  during  school  hours.   The  evacuation  plans  call  for  school  children  to 
be  bused  to  special  reception  centers  directly  from  school,  but  the  emergency 
booklet  does  not  list  the  locations  of  those  centers. 

We  also  found  that  the  Carver  residents  we  surveyed  exhibited  a  noticeably 
lower  degree  of  familiarity  with  emergency  procedures  than  residents  of  the 
other  three  towns  within  the  EPZ.   Thirty-six  percent  of  Carver  residents,  for 
example,  said  they  had  never  heard  the  Pilgrim  warning  siren  (compared  to  13% 
for  residents  of  Plymouth)  (Q.  3).   Not  surprisingly,  then.  Carver  residents 
were  the  least  likely  to  be  able  to  distinguish  the  Pilgrim  warning  from  other 
warning  sirens  (Q.  7). 

The  survey  as  a  whole  reveslfid  a  genera''  Icck  of  information  on  the  part 
of  the  public.   But  Carver  residents  also  displayed  a  surprising  amount  of 
misinformation  about  the  evacuation  plans.   Two-thirds  of  those  who  said  they 
would  go  to  one  of  the  evacuation  centers  in  case  of  an  accident  named  the 
wrong  center  for  their  area  (Q.  14). 


256 


It  is  clear  that  Boston  Edison  needs  to  make  additional  efforts  to  include 
Carver  in  warning  drills  and  to  counter  misinformation  about  the  evacuation 
plans. 

The  confusion  and  panic  that  could  spread  from  large  numbers  of  people  not 
knowing  what  to  do  in  a  pressure-filled  situation  might  be  impossible  to  quell. 
But  ignorance  of  the  Pilgrim  emergency  plans  is  far  from  the  only  problem  we 
found. 

B.   RESIDENTS  WILL  NOT  FOLLOV  THE  EMERGENCY  PLANS 
Several  survey  responses  suggeot  dtront^j.)  that  many  people  in  the  EPZ 
would  not  follow  the  procedures  outlined  in  the  emergency  planning  booklet 
even  if  they  were  familiar  with  them.   This  finding  represents  perhaps  the 
most  serious  challenge  to  the  workability  of  the  Pilgrim  emergency  plans. 

Many  recurrent,  unsolicited  comments  made  by  survey  respondents 
demonstrated  a  pervasive  belief  that  the  emergency  plans  do  not  represent  a 
sensible  response  to  a  serious  accident  at  Pilgrim.   In  case  of  a  serious 
accident,  the  first  thing  many  respondents  would  do  is  "pray"  or  "Iciss  my  wife" 
or  "panic."  Evacuees  would  head  not  to  one  of  the  emergency  reception  centers 
but  "whichever  way  the  wind  isn't  blowing."   How  will  the  authorities  warn 
people  in  case  of  an  accident?   A  surprising  number  answered,  "What  difference 
does  it  make?" 

The  conclusion  that  EPZ  residents  would  not  follow  the  emergency  plans  is 
not  based  merely  on  these  off-the-cuff  remarks.  Many  of  the  "hard  numbers" 
point  in  the  same  direction.  Just  19%  of  those  polled,  for  example,  said  they 
would  follow  the  evacuation  plan  outlined  in  the  emergency  information  booklet 
(Q.  lA) .  While  a  large  part  of  the  reason  for  this  low  number  could  simply  be 
ignorance  of  the  plans  (see  previous  section),  only  2%  of  those  answering  the 
same  question  said  that  they  would  go  wherever  directed,  indicating  little 

10 


257 


willingness  to  wait  for  evacuation  planners  to  provide  any  advice  (Q.  14). 

The  survey  also  showed  thitt  most  residents  who  have  children  m  school  in 
the  area  will  not  follow  the  existing  evacuation  plans  in  the  event  of  an 
accident  at  Pilgrim.   If  such  a  situation  were  to  arise,  just  3%  of  parents 
said  they  would  wait  for  their  children  to  come  home  from  school  and  only  9X 
would  attempt  to  meet  them  outside  the  danger  zone,  as  the  emergency  booklet 
advises.   Forty-eight  percent  said  they  would  trv  to  pick  their  children  up 
from  school  —  precisely  the  thing  they  are  not  supposed  to  do.   Another  37% 
did  not  know  what  they  would  do  or  gave  another  answer  (Q.  18). 

Again,  only  a  part  of  this  response  is  due  to  ignorance.   Ever,  when 

specifically  informed  of  the  proper  procedures  to  follow  in  case  a  family 

member  were  in  school  or  a  hospital  during  an  evacuation,  barely  over  half 

(51%)  of  the  respondents  thought  they  "would  be  able"  to  follow  instructions 

directing  them  not  to  try  to  pick  up  their  family  members  themselves.   Those 

who  gave  a  reason  for  for  disobeying  the  instructions  typically  explained  that 

they  simply  could  not  entrust  the  safety  of  a  family  member  to  the  authorities, 

that  this  was  their  responsibility  (Q.  22). 

TABLE  2 

WHAT  PARENTS  OF  SCHOOL -AGE  CHILDREN  WOULD  DC  IN  CASE  OF  AN  ACCIDENT  AT  PILGRIM 

DURING  SCHOOL  HOURS 

%   of  Parents  With 
Number    Children  in  Area  Schools 

Get  children  from  school  65  48 

Wait  for  them  to  come  home          4  3 

*Meet  them  outside  danger  zone  13  9 

Other  27  20 

Don't  know  22  17 

*  Correct  answer,  according  to  emergency  planning  booklet. 

(Based  on  responses  to  Question  18) 

11 


258 


C.   THE  EMERGENCY  PLANS  DO  NOT  ADDRESS  THE  NEEDS  OF  MANY  POPITLATION  GROUPS 
As  the  Federal  Emergency  Management  Agency  has  finally  acknowledged,  lack 
of  education  and  widespread  distrust  are  not  the  only  problems  with  the 
Pilgrim  emergency  plans.   Our  survey  revealed  that  the  plans  fail  to 
adequately  address  the  needs  of  families  with  children,  the  elderly,  and  those 
who  have  lived  in  the  area  for  three  years  or  less. 

1.  FAMILIES  WITH  CHILDREN 
Whether  because  of  the  lack  of  an  aggressive  public  education  program  or 
simply  because  of  a  poorly  designed  plan,  an  ai-tempt  to  evacuate  families  with 
school-age  children  according  to  the  existing  plans  will  almost  surely  meet 
with  failure.   This  constitutes  perhaps  the  most  serious  flaw  in  the  emergency 
plans. 

More  than  a  third  (3  7%)  of  the  people  surveyed  have  children  under  16  who 
go  to  school  in  the  Pilgrim  area  (Q.  16).  Few  of  them  would  be  either  willing 
or  able  to  follow  the  evacuation  procedures  outlined  in  the  emergency  plans  if 
an  accident  were  to  occur  during  school  hours.  As  noted  in  section  B  and  Table 
2  above,  virtually  half  of  parents  surveyed  (48%)  would  actually  do  whet  the 
emergency  planning  booklet  tells  them  not  to  do  —  pick  up  their  children  from 
school  themselves. 

The  evacuation  plans  are  premised  on  a  smooth  flow  of  traffic  in  a 
specific  direction  along  the  designated  routes.   A  significant  portion  of  the 
population  trying  to  get  to  schools  all  over  the  EPZ  would  seriously  disrupt 
planned  traffic  patterns.   Though  the  evacuation  plans  call  for  school  children 
to  be  transported  directly  to  special  evacuation  centers,  seven  out  of  ten 
parents  we  spoke  to  would  not  know  where  to  find  their  children  if  that 
happened  (Q.  19). 

A  different  set  of  problems  would  arise  if  an  accident  occurred  after 

12 


259 


school  hours  but  while  many  prirents  were  still  at  work.   More  than  a  third  of 
the  parents  we  polled  tcl^  us  that  their  children  are  sometimes  left  unattended 
after  school  lets  out  (0.  17).   .\ccording  to  the  emergency  booklet,  parents 
away  from  their  homef  "may  not.  be  pf='rmitteQ  to  return  [to  the  affected  areas] 
during  the  evacuation,''  leavirg  unknown  numbers  of  children  to  fend  for 
themselves. 

2,   rue  ELDERI.Y 

Many  of  the  problems  we  found  with  the  Pilgrim  emergency  plans  are  simply 

exacerbated  when  dealing  with  those  65  and  older.   This  group  of  survey 

respondents  had  even  le&s  familiarity  with  the  plans  than  did  the  general 

population.   More  than  a  fourth  did  not  know  that  there  is  an  emergency 

evacuation  plan  in  case  of  an  nceident  at  Pilgrim;  few  knew  that  warnings 

and  information  would  be  sent  out  over  local  television  and  radio  (Q.  1,  2, 

12).   And  even  if  they  were  to  hear  a  warning  siren,  a  third  doubted  whether 

they  would  know  what  the  warning  was  for  (Q.    7). 

TPSl.^   3 

FAMILIARITY  WITH  EMHPGENCY  PROCEDURES:   RESPONDENTS  AGE  65  AND  OVER 
COMPARED  WITH  GENERAL  POPULATION 

%   of  Total   %  of  Respondents 
Responses Age  65  and  Over 

Aware  that  emergency  plans  exist  for 

your  town?  Ye.=!  87  7A 

26 

How  will  people  be  warned  of  Pilgrin 

accident?  Siren        75  64 

6 
14 
Gould  distinguish  Pilgrim  siren  iru_. 

other  sirens?  Yes  5  9  45 


Know  how  to  get  instructions  in  cir,£ 
of  emergency? 


Ye.=! 

87 

No 

13 

Siren 

75 

r//Radio 

19 

Don't   Know 

10 

Yes 

59 

No 

21 

TV/Padic 

33 

Other 

9 

No 

57 

29 

19 

6 

72 


(Based   on    response;^    to  Questions    1,    2,    7   and    12) 


13 


260 


The  elderly  also  face  one  problem  that  most  others  (aside  from  children) 
in  the  EPZ  do  not:   lack  of  acc<?s6  to  an  automobile.   At  any  given  time,  as 
many  as  12%  of  these  over  65  would  not  have  a  car  available  for  their  use, 
compared  with  two  or  three  percent  in  the  general  population  (Q.  20).   Locating 
and  transporting  these  people  may  present  a  difficult  problem  for  evacuation 
planners. 

3.   NEWER  RESIDENTS 
Those  who  have  lived  in  the  Emergency  Planning  Zone  for  three  years  or 
less  are,  in  general,  the  least  well  informed  about  emergency  planning  and 
about  the  Pilgrim  plant  in  general.   Forty-seven  percent  of  these  newer 
residents,  who  make  up  nearly  a  quarter  of  all  those  we  surveyed,  had  not 
received  a  copy  of  the  emergency  planning  booklet  (Q.  9).   Moreover,  only  half 
of  them  have  ever  heard  the  Pilgrim  warning  siren,  compared  with  more  than  80% 
of  the  rest  of  those  we  surveyed  (Q.  3).   All  the  problems  associated  with 
ignorance  of  the  emergency  procedures  discussed  above  thus  apply  with  even 
greater  force  to  this  large  demographic  group. 

It  is  unlikely  that  this  problem  is  the  result  of  apathy  on  the  part  of 
those  new  to  the  area.  Among  new  residents  who  initially  thought  that  the 
Pilgrim  plant  should  be  reopened  (Q.  25),  more  than  three-fourths  (77%) 
changed  their  opinion  when  informed  that  the  NRC  had  found  serious  safety  and 
management  problems  at  the  plant,  compared  to  a  54%  turnaround  among  the  total 
sample  (Q.  26).   This  was  the  largest  turnaround  we  found,  strongly  suggesting 
that  it  is  simply  lack  of  information  which  distinguishes  these  residents  from 
others.   Boston  Edison's  failure  to  reach  any  more  than  half  of  these 
residents  with  emergency  information  or  warning  drills  thus  could  be  a  primary 
cause  of  their  inability  to  cope  effectively  with  an  emergency  situation. 


14 


261 


J.   niE  Bl.AWS  REVHALEi:  3Y  T!'E  L^URVSY  RENDER  THE  F.^;ERGHNC•y  PLANS  UNWORKABLE 
The  probleas  ou'.J  med  in  the  ;;reced.irg  rhree  sections  reveal  significant 
defects  in  both  the  design  and  iiipi'tnentat  ion  of  emergency  plans  for  the 
Pilgrim  area.   Much  of  the  affected  population  is  unfairiiliar  with  basic 
elements  of  the  plana,  many  who  are  familiar  with  the  plans  will  not  follow 
them,  ana  the  needs  cf  identifiable  groups  of  people  have  simply  not  been 
addressed  either  in  the  plans'  design  or  in  the  dissemination  of  emergency 
information. 

Our  survey  uncovered  a  number  of  other  problems  which,  combined  with  those 
mentioned  above,  will  make  an  GVijCUj.:ion  uiiwoikaiilt . 

1 .   PRESENT  VJARNING  METHODS  ARE  UNLIKELY  TO  ALERT  RESIDENTS  QUICKLY 
It  seems  apparent  from  out  findings  that  a  significant  number  of  residents 
might  not  receive  effective  warring  and  accurate  information  quickly  enough  to 
be  of  any  use  during  the  short  time  in  which  a  serious  accident  could  develop. 

Use  of  the  v;arriing  sirens  alone  is  not  enough.   Over  40%  of  those  we 
surveyed  said  that  they  could  not  hear  the  sirens  well  or  at  all  when  their 
doors  and  windows  were  closed  (Q.  4).   In  addition,  many  of  those  who  are 
familiar  with  the  sirens  have  heard  them  sl'  often  ("everv  time  there  is  an 
electrical  storm")  that  simply  heading  a  siren  would  not  immediately  alert 
them  to  an  actual  accident  in  progress  (Q.  3,  6). 

2.   PHONE  LINES  ARE  LIKF.LY  TO  BE  TIED  UP  DURING  AN  EMERGENCY 
Only  a  third  of  our  survev  sample  knew  that  emergency  information  would  be 
available  on  local  television  and  radio  (Q.  12';.   It  is  not  surprising,  then, 
that  nearly  two-thirds  of  the  pe'^nle  we  polled  rsid  that  thev  would  use  the 
telephone  to  find  out  emergencv  information  or  to  find  cut  information  about 
family  members  (Q.  13).   This  ie  particularly  i:nderstandable  in  light  of  the 
fact  that  the  emergency  information  booklet  contains  no  instructions  against 


15 


262 


y;;-'.ng  the  Telephone  during  en  eiotTgency. 

Thousands  of  peoplp  all  picking  up  the  phone  at  nearly  the  same  time  is 
sure  to  tie  up  phone  lines  and  make  communication  virtually  impossible,  further 
hindering  an  effective  response  to  a  serious  accident  at  Pilgrim. 

3.   ORDERLY  EVACUATION  IS  UNLIKELY  TO  OCCUR 
The  obstacles  facing  those  trying  to  devise  a  way  of  evacuating  all  the 
residents  of  the  EPZ  in  case  of  a  serious  accident  at  Pilgrim  may  well  be 
insurmountable  under  the  best  conditions.   The  problems  already  discussed 
above  make  it  abundantly  clear  that  those  planning  for  evacuation  now  are 
operating  in  a  situation  that  is  far  from  ideal. 

The  lack  of  familiarity  with  the  existing  plans  and  the  lack  of  confidence 
that  those  plans  will  work  are  the  most  obvious  problems.   Although,  directed  to 
stay  inside  and  wait  for  instructions  by  the  emergency  information  booklet,  the 
initial  response  to  an  accident  situation  among  many  of  those  we  surveyed 
included  evacuation  (27%),  making  phone  calls,  packing,  and  gathering  the 
family  (9%,  2%,  and  12%,  respectively),  and  a  variety  of  responses  subsumed 
under  the  categories  of  "don't  know"  and  "other"  (12%  and  18%,  respectively) 
(Q.  11).   Those  who  would  evacuate,  even  if  properly  directed  to  do  so,  would 
flee  in  all  possible  directions  —  "whichever  way  the  wind  isn't  blowing,"  in 
the  words  of  one  respondent  —  forsaking  the  planned  escape  routes  mapped  out 
in  the  booklet  (Q.  lA,  15).   For  many  that  is  not  an  irrational  decision: 
Hanover  Mall,  one  of  the  evacuation  centers  listed  in  the  current  emergency 
information  booklet,  has  withdrawn  as  an  evacuation  center! 

An  intensive  program  of  public  education  could  perhaps  overcome  some  of 
the  flaws  identified  in  the  survey.   It  is  uncertain,  however,  whether 
education  would  be  enough  to  convince  parents  of  young  children,  or  people  with 
family  members  in  a  hospital  or  nursing  home,  to  leave  their  family  members  to 


16 


263 


th'-'  autboritie'j  Cor  e\'acuation.  The  plan  simply  does  not  take  into  account  the 
strong  impulse,  particularly  of  parents,  to  see  to  the  safety  of  their  children 
themselves  (Q.  18,  22). 

Finally,  the  evacuation  plan  depends  primarily  on  most  residents'  ability 
tc  get  themselves  out  of  the  danger  zone,  with  emergency  workers  left  to  see  to 
any  others.   Our  survey  showed  that  approximately  95%  of  the  people  in  the  EPZ 
have  access  to  a  car  at  any  given  time  (Q.  20).   The  effect  of  nearly  every 
automobile  in  the  towns  of  Plymouth,  Carver,  Kingston  and  Duxbury  taking  to  the 
reads  at  the  same  time  is  unprecedented  and  almost  unimaginable.   Add  to  that 
number  the  residents  of  the  area  surrounding  the  Pilgrim  EPZ.   During  the  Three 
Mile  Island  emergency,  for  example,  when  authorities  ordered  2,500  women  and 
young  children  to  evacuate  14A,000  people  took  to  the  roads. 

One  respondent  commented  that  it  is  virtually  impoesible  to  get  through 
traffic  when  there  is  a  snowstorm  and  a  few  cars  break  down;  he  could  not 
conceive  of  the  problems  that  would  ensue  if  the  entire  town  of  Plymouth  tried 
to  leave  at  once.   Most  Massachusetts  residents  are  familiar  with  the 
monumental  traffic  problems  caused  by  Cape  Cod  traffic  on  a  summer  weekend. 
Snarls  such  as  these  would  almost  certainly  be  dwarfed  by  those  resulting  from 
a  full-scale  evacuation  of  the  Pilgrim  EPZ. 

The  number  of  cars  on  the  road  would  also  make  it  far  more  difficult  for 
emergency  workers  and  buses  to  get  through  to  the  school  children  and  elderly 
who  cannot  transport  themselves  out  of  town.   Ironically,  the  widespread 
availability  of  cars  might  prove  the  greatest  obstacle  to  getting  people  out  of 
the  danger, zone  in  time  to  protect  them  from  a  radiation  release. 

E.   MOST  RESIDENTS  SURVEYED  WANT  PILGRIM  TO  REMAIN  SHUT  DOWN 
In  light  of  the  serious  problems  which  beset  the  emergency  plans  and  the 
^oor  safetv  record  compiled  by  the  Pilgrim  plant,  the  residents  surveyed  have 
arrived  at  the  following  response  to  this  situation:   keep  the  plant  shut  down. 

17 


264 


When  asked  simply  whether  they  favored  reopening  the  plant  after  its 
scheduled  maintenance  and  refueling,  55%  said  that  it  should  remain  shut  down 
and  only  34%  favored  reopening  (Q.  25).   When  those  who  had  not  answered  "shut 
down"  were  informed  that  the  NRC  had  found  serious  management  and  safety 
problems  at  the  Pilgrim  plant,  more  than  half  changed  their  answer  and  said 
that  if  those  findings  were  correct,  the  plant  should  remain  shut  down. 

Combining  the  responses  to  these  two  questions,  79%  of  the  entire  survey 
sample  favored  shutdown  in  response  to  either  Question  25  or  26,  with  just  17% 
still  favoring  operation  of  the  plant  after  be:ing  asked  both  questions. 
Significantly,  this  response  held  true  across  all  political  and  demographic 
categories:   liberals  and  conservatives,  young  and  old,  high-school-  and 
college-educated  people,  residents  of  all  four  towns,  and  even  households 
containing  Boston  Edison  employees  favored  shutdown  of  Pilgrim  (Q.  25  &  26: 
Combined  Answer). 

Thus,  a  clear  majority  of  Pilgrim-area  residents  already  favor  shutdown 
of  the  Pilgrim  nuclear  power  plant.   After  learning  more  about  official  views 
of  the  plant's  safety,  they  favor  shutdown  by  nearly  a  five  to  one  margin. 

Much  of  this  sentiment  can  be  attributed  to  lack  of  faith  in  Boston 
Edison.   When  asked  who  they  would  trust  for  information  and  advice  during  an 
emergency,  our  survey  sample  expressed  the  greatest  distrust  for  Boston  Edison 
officials.   Thirty-one  percent  said  they  would  have  no  confidence  in  their 
advice;  the  next  highest  negative  rating  was  17%.   Boston  Edison  also  had  the 
second-lowest  positive  rating  (coming  in  just  ahead  of  the  faceless 
"independent  expert")  and  the  lowest  overall  confidence  score  (Q.  23). 


18 


265 


Hi.   DETAILED  SUMMARY  OF  QUESTIONS  AND  RESPONSES 
A.   METHODOLOGY 

The  survey  is  based  on  363  telephone  interviews  with  adult  residents  of 
che  towns  of  Plymouth  (including  Manomet),  Carver,  Duxbury  and  Kingston.   These 
towns  comprise  the  emergency  planning  zone  for  the  Pilgrim  Nuclear  Power 
Station. 

The  questionnaire  consisted  of  3A  questions,  including  eight  questions  on 
demographic  variables.   Interviewing  was  conducted  from  May  5  to  May  14,  1987, 
by  MASSPIRG  researchers  acting  under  the  supervision  of  a  John  F.  Kennedy 
School  of  Government  graduate  student  trained  in  scientific  polling  methods. 

Telephone  numbers  for  interviews  were  chosen  randomly  by  computer  in  order 
to  reach  residents  with  unlisted  phone  numbers  and  new  residents  whose  numbers 
had  not  yet  been  published.   This  technique  yields  a  more  representative  sample 
of  households  than  use  of  a  telephone  directory  to  generate  numbers. 

The  survey  was  a  stratified  random  sample.   This  technique  divides  the 
total  population  into  twelve  groups,  known  as  strata,  each  of  which  consists  of 
men  or  women  of  a  given  town  or  telephone  exchange.   Within  each  of  these 
strata,  individual  respondents  were  selected  totally  at  random.   The  number  of 
interviews  conducted  in  a  given  stratum  was  determined  in  advance,  according  to 
the  proportion  of  the  total  actual  population  represented  by  that  group  and  in 
order  to  produce  a  statistically  s- sni /^icant  'laiiple  frrm   each  tcwn.   Tne 
results  veve   then  weighted  based  on  the  share  of  actual  population  represented 
by  each  stratum;  the  totals  thus  refect  the  disLribution  by  town  and  gender  of 
the  actual  population,  not  of  the  sample  population. 

In  theory,  95  times  out  of  100  the  results  from  the  overall  sample  should 
differ  no  more  than  4  percentage  points  from  what  would  have  been  found  by 
purveying  the  entire  population  of  the  towns.   The  sampling  error  for  smaller 

19 


266 


eubgroups  (for  example,  a  particular  age  group,  or  residents  of  one  of  the 
towns)  could  be  larger,  depending  on  the  size  of  these  groups.   Other  errors 
can  result  from  the  usual  practical  problems  of  conducting  a  public  opinion 
survey. 

B.  THE  SURVEY 


Question  1.   DID  YOU  KNOW  THAT  THE  STATE  AND  LOCAL  GOVERNMENT  HAVE  DEVELOPED  AN 
EMERGENCY  EVACUATION  PLAN  TOR  YOUR  TOWN  IN  THE  EVENT  OF  A  SERIOUS 
ACCIDENT  AT  THE  PILGRIM  NUCLEAR  POWER  STATION? 


Total 
Numbei 

Responses 
r        % 

Kingston 

Number 

% 

Age  65  an< 
Number 

i  Over 
% 

Yes 

314 

87 

37 

80 

40 

74 

No 

49 

13 

10 

20 

14 

26 

This  threshold  question  revealed  that  most  respondents  were  aware  of  the 
existence  of  emergency  planning  for  their  community.   In  Kingston,  however,  20% 
of  those  surveyed  did  not  know  that  there  is  an  emergency  evacuation  plan  for 
their  town,  and  among  respondents  who  are  65  and  older,  more  than  one-fourth 
answered  "no"  to  this  question. 

Question  2.   IF  THERE  WERE  A  SERIOUS  ACCIDENT  AT  THE  PILGRIM  NUCLEAR  POWER 
PLANT  HOW  DO  YOU  THINK  THE  AUTHORITIES  WILL  WARN  PEOPLE? 
(list  all  responses) 


Siren 

TV  /  Radio 
Other 
Don't  Know 

The  correct  answer,  presented  on  page  1  of  the  official  emergency  planning 
booklet,  is  that  warnings  will  go  out  via  civil  defense  sirens,  police 
loudspeakers,  and  local  radio  and  television  stations.   While  three-fourths  of 
the  respondents  named  sirens  as  one  warning  mechanism,  fewer  than  one  in  five 
were  aware  that  warnings  would  be  issued  over  television  and  radio.   Again, 

20 


% 

of  Total 

Number 

Responses 

272 

75 

70 

19 

34 

9 

38 

10 

Number 

% 
Re 

of   Total 
isponses 

286 

79 

72 

20 

3 

1 

267 


those  over  65  displayed  the  leajt  awareness  of  emergency  procedures  (only  6A% 
mentioned  warning  sirens,  just  6%  named  TV/radio,  and  14%  did  not  know  how  they 
would  be  warned). 

Question  3.   HAVE  YOU  EVER  HEARD  THE  PIT, GRIM  WARNING  SIREN? 


Yes 

No 

Don't  Know 

.he  qui:cj.on,  hIZ    U^O)  said  they  have  heard  the 
siren  once  or  twice,  29%  (82)  have  heard  it  3  to  5  times,  and  17%  (48)  have 
heard  it  go  off  more  than  5  timas.   Twelve  percent  (36)  did  not  say  how  many 
times  they  had  heard  the  siren. 

More  than  a  third  of  the  Carver  residents  surveyed  (36%)  had  never  heard  the 
warning  siren,  while  86%  of  Plymouth  residents  reported  having  heard  it  at 
least  once.   Those  living  in  the  area  for  3  years  or  less  are  least  likely  to 
have  heard  the  siren  —  only  50%  of  those  surveyed  answered  "yes." 

Question  4.   HOW  WELL  CAN  YOU  HEAR  THE  PILGRIM  WARNING  SIREN  AT  YOUR  HOME  WHEN 
THE  WINDOWS  AND  DOORS  ARE  CLOSED? 

%  of  "Yes" 
Numbe r   to  Q.  3 

Well  95  33 

Somewhat  well  37  13 

Not  well  75  26 

Not  at  all  44  15 

Don't  Know  40  lA 

Only  46%  of  those  who  had  hearr,  the  sir^n  said  that  they  could  hear  it  well  or 
;iomewhat  well  when  the  doorr  and  .■:-''^"s  of  thrir  hoves   were  closed. 
demonstrating  the  need  for  additional  ways  of  warning  residents  in  case  of  an 
emergency. 


21 


268 


Question  5.   CAN  YOU  HEAR  POLICE.  FIRE  OR  AMBULANCE  SIRENS  AT  YOUR  HOME  WHEN 
YOUR  WINDOWS  AND  DOORS  ARE  aOSED? 


Yes 

Sometimes 

No 

Don • t  Know 


Number 

% 
Re 

of  Total 
isponses 

273 

75 

49 

13 

36 

10 

1 

0 

Question  6.   WHAT  DOES  IT  MEAN  WHEN  THE  PILGRIM  SIREN  GOES  OFF? 


Accident 
Drill 
Other 
Don't  Know 


Number 

% 
Re 

of  Total 
isponses 

109 

30 

70 

19 

118 

33 

77 

21 

"Other"  answers  included  many  "evacuate,"  "head  for  the  hills,"  "start 
packing,"  and  "kiss  your  ass  goodbye,"  indicating  that  respondents  would  think 
an  accident  was  in  progress  at  the  Pilgrim  plant.   (The  f rivolousness  or 
sarcasm  in  some  of  these  responses  indicates  that  many  residents  either 
do  not  take  the  sirens  seriously  or  do  not  believe  warnings  would  be  of  any  use 
were  a  serious  accident  to  occur,)   Another  group  of  "other"  answers,  such  as 
"another  thunderstorm,"  indicated  the  belief  that  hearing  the  siren  simply 
means  the  warning  equipment  is  malfunctioning. 


Question  7.   IF  YOU  HEARD  A  SIREN  RIGHT  NOW,  DO  YOU  THINK  YOU  COULD  TELL  THAT 
IT  WAS  BECAUSE  OF  PILGRIM,  RATHER  THAN,  SAY,  A  FIRE  ENGINE,  AN 
AMBULANCE.  OR  SOMETHING  ELSE? 

%  of  Total 


Yes,  could  tell 
Probably  could 
Probably  could  not 
No,  couldn't  tell 
Don't  know 


Number 

Res 

ponses 

215 

59 

35 

10 

11 

3 

77 

21 

15 

A 

22 


269 

Again.  Carver  residents  exhibited  the  least  amount  of  familiarity  with  the 
Pilgrim  warning  sirens:   nearly  half  —  45%  —  answered  that  they  could  not  or 
probably  could  not  distinguish  the  Pilgrim  siren  from  a  fire  engine  or  an 
ambulance.   Also,  one-third  of  respondents  aged  65  and  over  expressed  doubt 
that  they  could  recognize  the  Pilgrim  siren. 

Question  8.   HOW  WOULD  YOU  RECOGNIZE  THAT  A  SIREN  MEANT  A  NUCLEAR  ACCIDENT? 

%  of  Those  Answering 
Number Q.  7  Affirmatively 

High  pitch  25  10 

Steady  tone  26  10 

Very  loud  42  16 

Persistent  30  11 

Other  91  35 

Don't  know  61  23 

Although  a  majority  of  respondents  answered  that  they  would  recognize  the 
Pilgrim  siren  if  they  heard  it  (Q.  7),  few  respondents  correctly  explained 
how  they  would  tell  whether  a  real  accident  were  taking  place.   The  nuclear 
warning  siren  will  be  distinguishable  from  others  by  its  duration  (15  minutes), 
or  its  "persistence."  Only  11%  of  respondents  gave  this  answer.   The  most 
common  responses  of  those  categorized  under  "other"  were  that  the  siren  has  a 
"fluctuating"  or  "pulsating"  tone,  or  simply  that  "you  could  just  tell." 

Question  9.   HAVE  YOU  OR  ANYONE  IN  YOUR  HOUSEHOLD  RECEIVED  A  COPY  OF  THE 

BOOKLET  CALLED  "EMERGENCY  PUBLIC  INFORMATION:   WHAT  TO  DO  IN  CASE 
OF  AN  EMERGENCY  AT  PILGRIM  NUCLEAR  POWER  STATION"? 

Total  Responses  New  Residents  (<3  yrs) 

Number %  Number         % 

Yes  203  56 

Not  sure  /  maybe  42  11 

No  104  29 

Don't  know  11         3               4          4 

Although  Boston  Edison  claims  to  have  distributed  copies  of  this  booklet  to  all 
residents  of  the  emergency  planning  zone  in  November  1986,  nearly  one-third  of 
those  we  surveyed  (29%)  had  not  received  a  copy,  and  another  11%  were  not  sure 
if  they  had  received  one.   These  distribution  problems  were  most  critical  with 
regard  to  people  living  in  the  area  for  3  years  or  less,  who  made  up  nearly  a 
quarter  of  the  survey  sample:   47%  of  these  respondents  had  not  received  the 
emergency  planning  booklet,  compared  to  only  41%  who  were  sure  they  had. 

23 


33 

41 

6 

7 

39 

47 

270 


Question  10.   WOULD  YOU  SAY  YOU  HAVE  READ  THE  BOOKLET  COMPLETELY.  PARTIALLY.  OR 
NOT  AT  ALL? 


Number 

% 

of 

"Yes"  01 

to  Q. 

:  "Maybe" 

% 
Re 

of  Total 
:sponses 

Completely 

82 

33 

23 

Partially 

109 

44 

30 

Not  at  all 

45 

18 

* 

Among  those  who  said  they  had  received  or  may  have  received  the  emergency 
planning  booklet,  a  full  62%  admitted  that  they  had  read  it  only  partially  or 
not  at  all.   In  other  words,  only  23%  of  the  total  surveyed  said  they  had  read 
the  booklet  completely.   The  lack  of  actual  knowledge  of  emergency  procedures 
that  this  implies  is  corroborated  by  the  answers  to  many  other  questions  in 
this  survey. 

*  The  number  who  have  not  read  the  booklet  is  actually  much  larger  than  45, 
since  this  question  was  not  asked  of  those  who  never  received  the  booklet. 

Question  11.   IN  CASE  YOU  HEAR  THE  WARNING  SIREN.  INDICATING  A  SERIOUS  PROBLEM 
AT  PILGRIM.  WHAT  IS  THE  VERY  FIRST  THING  THAT  YOU  WOULD  DO? 


Turn  on  radio  or  TV 

Take  shelter  at  home 

Get  family  together 

Make  phone  calls 

Start  packing 

Evacuate 

Other* 

Don't  know 

*  Common  responses  include: 

"Panic"  (5  respondents) 
"Pray"  (6) 

"Kiss  my  wife/husband"  (2) 
"Get  drunk/grab  a  six"  (6) 

This  question  was  designed  to  find  out  what  people  would  in  fact  do.  as  opposed 
to  what  they  think  they  are  supposed  to  do.   Only  10%  said  that  they  would  take 


Number 

% 
Re 

of  Total 
isponses 

65 

18 

37 

10 

42 

12 

32 

9 

9 

2 

99 

27 

66 

18 

42 

12 

24 


271 


shelter  at  home,  as  the  emergency  planning  booklet  directs  on  page  3;  only  18% 

said  they  would  turn  on  the  radio  or  TV  to  get  information  or  instructions, 

which  the  booklet  also  recommends  (there  is  a  degree  of  overlap  in  these 

figures,  as  some  respondents  gave  more  than  one  answer). 

Significantly,  the  most  frequently  named  response  was  "evacuate,"  and  a  number 
of  other  responses  —  such  as  "start  packing"  and  many  responses  categorized 
under  "other"  —  were  premised  on  immediate  evacuation,  contradicting  the 
express  directions  in  the  emergency  planning  booklet. 

Question  12.   DO  YOU  KNOW  WHAT  THE  OFFICIAL  EMERGENCY  H.AN  RECOMMENDS  THAT  YOU 
DO  TO  GET  SPECIFIC  INSTRUCTIONS  IN  CASE  OF  AN  EMERGENCY? 

%  of  Total 
Numbe  r Responses 

Yes:   turn  on  radio/TV      120  33 

Yes:   other  31  9 

No  206  57 


Only  one  in  three  respondents  knew  the  correct  response,  "tune  to  local  radio 
and  TV  stations,"  which  is  listed  on  page  3  of  the  emergency  information 
booklet.   Even  more  disturbing,  fewer  than  one  in  five  respondents  65  or  over 
(19%)  gave  the  correct  response  to  this  question,  reiterating  the  concern  that 
the  elderly  may  present  difficult  problems  for  emergency  planners. 

Question  13.   WOULD  YOU  USE  THE  TELEPHONE  TO  FIND  OUT  EMERGENCY  INFORMATION  OR 
TO  FIND  OUT  INFORMATION  ABOUT  FAMILY  MEMBERS? 


Number 

%  of  Total 
Responses 

226 
117 

62 
32 

Yes 

No 

Don't  knew  16  4 

Surprisingly,  the  emergency  information  booklet  does  not  advise  people  not  to 
use  the  telephone  in  case  of  an  emergency.  Accordingly,  nearly  two-thirds  of 
those  we  surveyed  said  that  they  would  use  the  phone  —  primarily  to  call  the 
police  for  information  or  to  try  to  contact  family  members.  In  all  likelihood, 
this  will  only  serve  to  tie  up  phone  lines  and  jeopardize  efficient  execution 
of  the  emergency  plans. 


25 


272 


Question  14.   IF  THERE  WERE  AN  ACCIDENT  AT  PILGRIM  AND  YOU  WERE  TO  ACTUALLY 
EVACUATE  YOUR  HOME.  WHERE  WOULD  YOU  GO? 


% 

of  Total 

Number 

Responses 

Hanover  Mall 

46 

13 

Bridgewater  State  Colle 

•ge 

20 

5 

Taunton  State  Hospital 

3 

1 

Elsewhere  in  Mass. 

91 

25 

Wherever  directed 

7 

2 

Other* 

119 

33 

Don't  know 

65 

18 

*  Representative  responses  include: 

"Whichever  way  the  wind  isn't  blowing" 

"Roads  would  be  jammed  up/would  never  get  out  of  town" 

"Alaska/Canada/Califomia/Vermont/Miseissippi" 

"Good  questioni" 

Only  19X  of  the  respondents  said  they  would  go  to  one  of  the  evacuation  centers 
named  in  the  emergency  information  booklet  (the  first  three  responses  listed 
above).   IVo-thirds  of  these  people  (13X)  would  go  to  the  Hanover  Mall,  which 
has  already  pulled  out  of  the  evacuation  plan  and  will  not  serve  as  a  reception 
center,  but  which  is  still  listed  as  one  in  the  booklet. 

It  is  clear  from  these  responses  that  a  real  evacuation  would  produce  chaos. 
Only  22  of  those  surveyed  would  listen  first  for  directions,  confirming  the 
conclusion  suggested  by  Question  12  that  few  people  would  know  to  wait  and  tune 
in  to  local  media  for  emergency  information.   Moreover,  many  of  those  who 
profess  knowledge  of  the  actual  plans  are  misinformed:   for  example,  two-thirds 
of  the  Carver  residents  who  said  they  would  go  to  an  evacuation  center  named 
the  wrong  one. 

Even  those  supposedly  "in  the  know"  evidenced  a  shocking  lack  of  confidence  in 
the  evacuation  plans.   Although  the-  sample  size  is  admittedly  very  small,  only 
2  of  15  respondents  from  households  containing  Boston  Edison  employees  and  only 
4  of  20  from  households  containing  someone  responsible  for  implementing  the 
evacuation  plans  said  they  would  go  to  one  of  the  evacuation  centers  in  case  of 
an  accident  at  Pilgrim. 


26 


273 


Question  15.   DO  YOU  KNOW  WHAT  ROUTE  YOU  ARE  SUPPOSED  TO  TAKE  TO  GET  THERE  [TO 
THE  EVACUATION  CENTER]? 

%  of  Those  Who  Said  They 
Number Would  Go  To  an  Evacuation  Center 

Yes  A3  62 

No  23  3A 

This  question  tested  the  knowledge  of  the  evacuation  routes  mapped  out  in  the 
emergency  information  booklet  (pp.  ^-5)  among  those  respondents  who  said,  in 
response  to  Question  lA,  that  in  case  of  an  emergency  they  would  go  to  one  of 
the  evacuation  centers.   Even  among  this  self-selected  group,  one-third 
admitted  that  they  did  not  know  the  recommended  route. 

Question  16.   DO  YOU  HAVE  ANY  CHILDREN  AGE  16  OR  YOUNGER  WHO  GO  TO  SCHOOL  IN 
THE  AREA? 

%  of  Total 
Number Responses 

Yes  13A  37 

No  226  62 

Question  17.   ARE  THERE  ANY  TIMES  AFTER  SCHOOL  HOURS  WHEN  YOUR  CHILD (REN) 
IS (ARE)  NOT  IN  THE  CARE  OF  AN  ADULT? 

%   of  "Yes"  to 
Number Q.  16 

No  83  62 

Yes  50  37 

In  case  of  an  emergency  at  Pilgrim  during  after-school  hours,  as  many  as  37%  of 
children  16  or  under  could  be  left  to  fend  for  themselves.   Parents  at  work 
during  these  times  "may  not  be  permitted  to  return  [to  the  affected  areas] 
during  the  evacuation,"  according  to  the  anergency  information  booklet  (p.  6). 

Question  18.   IF  THERE  IS  AN  ACCIDENT  AT  PILGRIM  DURING  SCHOOL  HOURS,  WHAT 
WOULD  YOU  DO  ABOUT  YOUR  CHILD (REN)? 

Z  of  "Yes"  to 
Number Q.  16 

Get  children  from  school  65  A8 

Wait  for  them  to  come  home  A  3 

Meet  them  outside  danger  zone  13  9 

Other  27  20 

Don't  know  22  17 


27 


274 


The  correct  answer,  "meet  them  outside  the  danger  zone,"  was  given  by  only  9% 
of  the  respondents.   The  most  common  response  was  to  go  get  the  children  from 
school  oneself,  which  people  are  explicitly  instructed  not  to  do  on  page  6  of 
the  emergency  planning  booklet.   The  response  to  this  question  clearly 
indicates  either  a  major  flaw  in  the  evacuation  plans  or  the  need  for  intensive 
education  to  convince  parents  to  ignore  their  strong  impulse  to  find  their 
children  themselves. 


Question  19.   ACCORDING  TO  THE  OFFICIAL  EMERGENCY  PLAN.  YOU  ARE  SUPPOSED  TO 

MEET  THEM  AT  A  SPECIAL  EVACUATION  CENTER  AWAY  FROM  TOWN.   DO  YOU 
HAPPEN  TO  KNOW  WHERE  THE  CENTER  IS  WHERE  YOU  WOULD  FIND  YOUR 
CHILD (REN)? 

%  of  "Yes"  to 
Number Q.  16 

Yes  39  29 

No  92  69 

Adding  to  the  confusion  and  panic  that  an  evacuation  would  cause,  seven  out  of 
ten  parents  we  surveyed  would  not  know  where  to  find  their  children  if  an 
accident  occurred  at  Pilgrim  during  school  hours. 

Question  20.   DO  YOU  HAVE  A  CAR  AVAILABLE  FOR  YOUR  USE  DURING  . . . 

Total  Responses           Age  65  &  Over 
Number        %  Number  % 


WEEKDAYS? 

Yes 

344 

95 

49 

90 

No 

11 

3 

5 

10 

Sometimes 

5 

2 

0 

0 

WEEKNIGHTS? 

Yes 

340 

94 

47 

88 

No 

13 

3 

6 

12 

Sometimes 

4 

1 

0 

0 

WEEKENDS? 

Yes 

343 

94 

49 

90 

No 

9 

2 

4 

7 

Sometimes 

A 

1 

1 

2 

At  any  given  time,  95%  of  the  households  in  the  emergency  planning  zone  would 
have  a  car  available  to  be  used.   This  many  households  each  evacuating  in  a 
separate  automobile  at  the  same  time  will  likely  create  traffic  problems  of 
unprecedented  proportions,  particularly  in  light  of  the  fact  that  most  people 
surveyed  would  not  knew  to  use  the  evacuation  route  planned  for  their 
particular  section  of  the  EPZ  (see  questions  14  and  15) . 

Respondents  65  and  over  were  the  only  demographic  group  without  such  wide 
access  to  an  automobile.   7  to  12%  of  those  we  surveyed  would  not  be  able  to 


28 


275 


use  a  car  at  any  given  time,  creating  a  different  set  of  problems  for 
evacuating  this  group  of  residents. 


Question  21.   DOES  YOUR  HOME  HAVE  A  BASEMENT? 


Yes 
No 


Question  22.    SUPPOSE  YOU  WERE  ADVISED  TO  EVACUATE  BECAUSE  OF  AN  ACCIDENT  AT 
PILGRIM.  BUT  YOU  HAD  CHILDREN  IN  SCHOOL  OR  A  FAMILY  MEMBER  IN  A 
HOSPITAL  OR  NURSING  HOME.   ACCORDING  TO  THE  PLAN,  YOU  ARE 
SUPPOSED  TO  GO  DIRECTLY  TO  A  SPECIAL  EVACUATION  CENTER,  WHILE 
YOUR  FAMILY  MEMBERS  WERE  TRANSPORTED  TO  THEIR  APPROPRIATE 
LOCATIONS.   WOULD  YOU  BE  ABLE  TO  FOLLOW  THESE  INSTRUCTIONS? 


Number 

%   of  Total 
Responses 

313 
A7 

86 
13 

Number 

%  of  Total 
Responses 

185 
128 

51 
35 

Yes 

No 

Don't  know  A2  12 

This  question  is  similar  to  the  one  asked  of  parents  of  school-age  children 
(Question  18),  but  is  far  less  open-ended  and  more  likely  to  elicit  a  "yes" 
response.   First,  the  question  is  hypothetical  —  most  respondents  did  not  in 
fact  have  children  in  school  or  family  members  in  a  hospital  or  nursing  hone. 
Second,  the  question  spells  out  what  the  actual  evacuation  plans  are  in  a  way 
that  makes  them  sound  reasonable  and  workable.   Finally,  the  question  asks 
whether  the  respondent  "would  be  able"  to  comply  with  such  a  scheme  if 
instructed  to  do  so. 

In  spite  of  the  clear  slant  of  this  question,  nearly  half  those  surveyed  said 
that  they  either  would  not  follow  these  plans  or  did  not  know  whether  they 
could  follow  them.   The  vast  majority  of  those  answering  "no"  mentioned  their 
need  to  provide  for  the  safety  of  their  family  members  themselves  and  not  to 
entrust  that  role  to  the  authorities.   As  was  clear  with  Q-jastion  18,  the 
strong  desire  of  people  to  find  their  family  members  indicates  either  a  major 
flaw  in  the  evacuation  plans  or  the  need  for  far  better  education  on  behalf  of 
Boston  Edison. 


29 


276 


Question   23.       IF   THERE  WERE   Mi  ACCxji^.f  A'^    PiLGRIK.    YOU   t-IIGHT  HEAR   STATEMENTS 

ON   THE   RADIO   OR  OK   1/   "Y   l/I I'^  RENT    .'EOPLE    AND   ORGANIZATIONS.       I'M 
GOING  TO   MENTIOn   S0.~;   CT   IHF.M.    AND   AS    I   DO.    PLEASE  TELL   ME   FOR 
EACH  ONE    HOW   MUCT    CO:"  J'' ""Cn   YOU  WOULD   HAVE    IN   THEM  TO   GIVE  YOU 
ACCURATE    INFO KMAT low  A:ID   COOu   AJ)VICE.      A   SCORE   OF   5   MEANS   THAT 
YOU   HAVE   A  GREAT  D'  '',   OF   COiriDI^NCE   IN   THEM;    A   SCORE  OF    1   MEANS 
THAT   YOU   HAVE   MO   OJ'.'l'Il'lznr^    I!'   T.iSIR  /J3VICE;    A   SCORE   OF   3   WOULD 
BE    SOMEWHERE    If!   ''.i::^,   >rB'i..':. 


Governor  Dukakis 

An    official    of   Boston 
Edison 


tIJII 

3" 

\nt 

:'ering 
I12II 

"1" 

DK 

Avei 
Sec 

3 

-age 
3re*a 

36 

->  - 

.r 

6 

17 

2 

54 

19 

•  -} 

io 

ii 

31 

2 

2 

81 

An   official    of    the  U.S.      34 
Nuclear   Regulatory    Comm. 


16 


3.51 


Attorney  General  Shannon  19 
An  independent  expert    15 


12 

17 


18 
10 


3.30 
3.01 


Boston  Edison  received  easily  t-,  :     ,l  -ar'.;-  of  any  of  the  people  or 
organizations  we  mentioned,  garr^rin,^  ^.,e   r.econd-lowest  positive  rating,  far 
and  away  the  highest  negative    ci"c;  :...'.    the  Iciest  average  score.   Even  among 
those  respondents  who  believ3  t".".t  ?il~r'.tp  chould  reopen  despite  findings  of 
serious  safety  problems  (see  Que.  tier. -3  25  c-^  26),  only  32%  expressed  a  great 
deal  of  confidence  in  emergency  i~for.i9tior  dissemin?.ted  by  Boston  Edison. 

*  "Average  Score"  was  computed  exclu'! '.ji[;  those  ans-.jering  "don't  know"  or  who 
refused  to  answer.   Thus,  Attorney  G-n^ral  Shannon's  3.30  score  must  be 
tempered  by  the  fact  that  18%  did  not  knov.  '•]'.''-':   a-iount  of  confidence  they  would 
have  in  him. 


Question  24.    DO  YOU  THINTC  TH/.T  IT  TS  LIKELY 
ACCIDENT  AT  THE  riLC-.xi:  FLA>i7: 


rH/T  THERE  WILL  BE  A  SERIOUS 


%  of  Total 
Responses 


Yes 


24 


Maybe 
No 


7-1 


.20 
',6 


Don't  know 


31 


Nearly  half  —  44%  —  of  thos=  s 
Pilgrim  is  either  likely  or  at  It  .1 
across  the  political  spectrum:  '• "  '  c* 


L.i*.  .  cJ: -t  1  serious  accident  at 
":i'Sli3.  Tliis  viewpoint  held  true 
-"..■■-fle"cribed  conservatives,  44%  of 


277 


liberals,  and  51%  of  moderates  answeved  either  "yes"  or  "maybe"  to  this 
question. 

Interestingly,  of  those  who  believed  that  Pilgrim  should  not  be  reopened  (see 
Questions  25  and  26),  only  53%  thought  a  serious  accident  is  likely  or  may  be 
likely.   This  total  is  just  slightly  larger  than  the  total  sample's  response  to 
Question  24,  suggesting  that  opposition  to  Pilgrim  runs  deeper  than  simply  fear 
of  a  serious  accident.   Other  issues  that  may  be  generating  public 
dissatisfaction  with  the  Pilgrim  plant  probably  include  waste  disposal,  smaller 
scale  radiation  releases,  and  unreliability. 


Question  25.   PILGRIM  IS  CURRENTLY  SHUT  DOWN  FOR  MAINTENANCE  AND  REFUELING.   IN 
YOUR  OPINION,  SHOULD  THE  PLANT  BE  REOPENED  OR  SHOULD  IT  REMAIN 
SHUT  DOWN? 


% 

of  To 

tal 

Number 

Re 

:sponses 

123 

34 

200 

55 

Reopened 

Shut  Down 

Other  15  4 

Don't  Know  24  7 

Over  half  of  those  polled  want  Pilgrim  to  remain  shut  down,  while  only  a  third 
believe  the  plant  should  reopen.   As  with  the  responses  to  Question  24,  this 
sentiment  cut  across  political  lines:   51%  of  conservatives,  60%  of  liberals, 
ana  59%  of  moderates  favored  shutdown. 

An  interesting  footnote  to  these  figures  was  the  response  of  people  from 
households  with  either  a  Boston  Edison  employee  or  someone  responsible  for 
implementing  the  emergency  plans  (15  and  20  respondents,  respectively).   While 
these  figures  are  not  statistically  significant,  it  is  nevertheless  noteworthy 
that  a  fifth  of  the  respondents  from  each  of  these  groups  favored  unequivocal 
shutdown  of  the  Pilgrim  plant. 

Question  26.   STUDIES  RECENTLY  COMPLETED  BY  THE  U.S.  NUCLEAR  REGULATORY 

COMMISSION  SHOW  INDICATIONS  OF  MANAGEMENT  AND  SAFETY  PROBLEMS  AT 
PILGRIM,  MAKING  IT  ONE  OF  THE  MOST  DANGEROUS  NUCLEAR  PLANTS  IN 
THE  COUNTRY.   IF  THESE  FINDINGS  ARE  CORRECT,  IN  YOUR  OPINION 
SHOULD  THE  PLANT  BE  REOPENED  OR  SHOULD  IT  REMAIN  SHUT  DOWN? 

%  of  Non-"Shut  Down" 
Number Responses  to  Q.  25 

Reopened  60  37 

Shut  Down  88  54 

Other  5  3 

Don't  Know  5  3 


31 


278 


This  question,  asked  only  of  those  not  answering  "shut  down"  to  Question  25,  is 
obviously  a  more  loaded  question  and  for  that  reason  was  the  last  question 
asked  in  the  survey,  so  as  not  to  taint  the  other  responses.   Only  slightly 
more  than  a  third  of  those  who  initially  favored  reopening  Pilgrim  still 
believed  the  plant  should  reopen  in  light  of  the  NRC's  findings  regarding 
safety  and  management  problems.   The  turnaround  was  most  dramatic  among  those 
who  had  lived  in  the  area  for  three  years  or  less,  a  group  making  up  23X  of  our 
total  sample.   77%  of  these  respondents  ans^vered  "shut  down"  to  this  question 
(compared  to  54%  on  Q.  25),  suggesting  that  many  newer  residents  simply  are  not 
yet  fully  informed  about  the  problems  that  have  historically  plagued  the 
Pilgrim  plant. 


Questions  25  and  26:   CO!  £  IKED 


Numbe  r 


%  of  Total 
Responses 


Answered  "Shut  Down"  to 
Q.  25  or  Q.  26 


288 


Answered  "Reopen"  to  Q.  26 


60 


Less  than  one  in  five  respondents  was  unequ:vocally  in  favor  of  reopening  the 
Pilgri"!  plant.   The  overwhelming  sentiment  in  favcr  of  shutting  down  an  unsafe 
nuclear  power  plant  was  consistent  across  all  demographic  lines: 

*  all  four  towns  in  the  survey  favored  shutdown  by  margins  ranging 
from  74%  (Carver)  to  90%  (Kingston); 

*  self-described  conservatives  were  77%  in  favor  of  shutdown, 
compared  to  84%  for  liberals,  82%  for  moderates,  and  72%  for  those 
who  could  not  or  would  not  describe  their  political  orientation; 

*  the  only  age  group  coming  in  at  less  than  70%  was  the  65  and  over 
group,  66%  of  whom  favored  shutdown; 

*  educational  backf^rour.d  slso  had  little  effect  on  shutdown 
sentiment:   the  percentag'is  in  fcvor  of  shutdown  varied  only  between 
75  and  83%  when  the  survey  sample  was  grouped  by  educational  level; 

*  even  among  those  from  households  containing  Boston  Edison 
employees  or  those  with  official  responsibilities  for  ir n1 ementing  the 
emergency  plans,  respondents  favoring  shutdown  outnumbered  those  in  favor  of 
reopening  the  plant  by  approximately  5  to  3. 


32 


279 


IV.   RECOMMENDATIONS 
Our  survey  of  Pilgrim  area  residents  shows  a  widespread  lack  of  knowledge 
about  emergency  planning  procedures,  little  faith  among  the  population  that 
the  evacuation  plans  are  workable  or  worth  complying  with,  strong  indications 
that  any  attempt  at  immediate  evacuation  would  meet  with  little  success,  and  a 
broad  consensus  behind  the  idea  that  a  nuclear  plant  with  a  safety  record  like 
Pilgrim's  should  remain  shut  down.   These  conclusions  are  surprising  only  to 
the  extent  that  they  present  an  even  poorer  picture  of  emergency  preparedness 
than  was  revealed  in  the  last  MASSPIRG  survey. 

MASSPIRG  and  a  variety  of  other  citizen  groups  and  local  and  state 
officials  have  consistently  argued  that  the  Pilgrim  emergency  plans  are 
themselves  a  disaster.   With  the  rapid  population  growth  in  the  Plymouth  area 
and  the  withdrawal  of  the  Hanover  Mall  as  an  evacuation  center,  the  plans  have 
deteriorated  even  further.   FEMA  has  withdrawn  its  approval  of  the  plans, 
calling  them  "inadequate  to  protect  the  public  health  and  safety  in  the  event 
of  an  accident."  Yet  Boston  Edison  is  nonetheless  considering  restarting  the 
plant  without  locally  and  federally  approved  plans. 

The  findings  in  this  report  clearly  demonstrate  that  restarting  the  plant 
under  the  existing  emergency  plans  could  prove  disastrous.   Given  the  current 
level  of  public  information  about  the  plans,  they  would  not  be  adequate  to 
protect  the  public  health  and  safety  even  if  the  deficiencies  identified  by 
FEMA  were  corrected.   Moreover,  because  residents  responded  that  they  would 
refuse  to  comply  with  key  elements  of  the  plans,  there  is  a  serious  question  as 
to  whether  any  plans,  no  matter  how  good  they  looked  on  paper,  could  be 
effectively  implemented. 

In  light  of  these  results  and  the  serious  management  and  safety  problems 
still  remaining  at  Pilgrim,  we  strongly  recommend  that  the  Pilgrim  plant  should 
not  reopen  until  it  is  determined  that: 

33 


280 


(1)  workable  plans  can  be  developed; 

(2)  such  plans  have  been  effectively  implemented  and  communicated  to  the 
public;  and, 

(3)  existing  management,  safety  and  economic  concerns  have  been 
adequately  addressed. 

We  call  on  Governor  Dukakis,  the  State  Legislature,  and  the  Massachusetts 
congressional  delegation  to  do  everything  within  their  power  to  keep  the 
reactor  closed  until  the  above  conditions  have  been  met. 

In  the  meantime,  MASSPIRG  continues  to  recommend  that  the  State  and  Boston 
Edison  explore  the  possibility  of  alternatives  —  such  as  efficiency  reforms, 
cogeneration.  small  power  producers,  and  conservation  —  which  have  the 
potential  to  produce  energy  more  safely,  cheaply  and  efficiently  than  does  the 
Pilgrim  nuclear  power  plant. 


i 


34 


281 


NUCLEAR  LEMON 


PUmu  OPETVkTIQN  vs.  nETfEMEMr 


I9a7  4 


UTTX 


ES 


RATEPAYER  SAVINGS  FROM  RETIRING 
THE  PILGRIM  NUCLEAR  POWER  PLANT 


Massachusetts  Public  Interest  Research  Group 
(MASSPIRG) 


NOVEMBER  1987 


282 


NUCLEAR  LEMON 


RATEPAYER  SAVINGS  FROM  RETIRING  THE 
PILGRIM  NUCLEAR  POWER  PLANT 


Massachusetts  Public  Interest  Research  Group 

(MASSPIRG) 

29  Temple  Place 

Boston,  MA  021 11 

(617)  292-4800 


Research  Director  and  Author: 

Alan  J.  Nogee 

Research  Assistant: 

Susan  Boehm 


November  1987 


283 


ACKNOWTLEDGMENTS 

The  author  gratefully  acknowledges  the  assistance  of  Susan  Boehm,  a 
graduate  student  at  the  John  F.  Kennedy  School  of  Government.  Thanks 
also  to  Stephen  Bernow,  of  the  Energy  Systems  Research  Group,  David 
Schlissel,  of  Schlissel  Engineering  Associates,  and  Chris  Granda,  of  the 
Legislative  Energy  Committee  for  invaluable  technical  input.  Armond 
Cohen,  of  the  Conservation  Law  Foundation;  Joshua  Kratka,  Rachel 
Shimshak,  Michael  L'Ecuyer,  and  WiUiara  Ryan,  of  MASSPIRG;  and 
Deborah  Horvitz,  my  wife,  provided  helpful  editorial  comments  on  early 
drafts  of  this  work. 


ABOUT  THE  AUTHOR 

Alan  Nogee  has  been  an  Energy  Policy  Analyst  for  over  ten  years.  He  is 
author  of  two  major  national  reports  on  utility  policy  -  Rate  Shock: 
Confronting  the  Cost  of  Nuclear  Power,  and  Gambling  for  Gigabucks:  Excess 
Capacity  in  the  Electric  Utility  Industry  ~  and  numerous  articles.  He  has 
testified  or  spoken  by  invitation  to  the  energy  committees  of  the  U.S.  Senate, 
House  of  Representatives,  National  Governors'  Association,  National 
Conference  of  State  Legislatures,  and  regulatory  agencies  and  legislative 
committees  in  several  states.  Before  joining  MASSPIRG  in  May,  1987,  he 
was  an  Energy  Analyst  with  Environmental  Action  Foundation,  in 
Washington,  D.C.,  and  for  consumer  and  environmental  groups  in 
Philadelphia,  Pennsylvania. 


284 


TABLE  OF  CONTENTS 


1.  Introduction  --  Nuclear  Costs  and  Cancellations 1 

2.  The  High  Cost  of  Operating  Pilgrim 4 

A.  Edison  ignores  nuclear  cost  trends 5 

B.  MASSPIRG  assumptions  are  still  conservative 7 

3.  Economic  Benefits  of  Retiring  Pilgrim 8 

A.  Replacement  power  costs  less  than  Pilgrim 8 

B.  Other  shutdown  costs 10 

C.  Ahemative  scenarios  show  savings  from  retiring  Pilgrim 12 

4.  Conclusions  and  Recommendations 15 

Appendix  A.  Annual  Costs  of  Pilgrim  vs.  Alternatives 16 

Appendix  B.  MASSPIRG  Nuclear  Cost  Estimates 23 

Appendix  C.  Causes  of  Nuclear  Cost  Escalation 29 

Notes 32 


LIST  OF  FIGURES 


Figure  1.  Pilgrim  Capital  Cost 2 

Figure  2.  Electricity  Generation  cost  --  1988 3 

Figure  3.  Pilgrim  Capital  Cost  Projection  (BECO  Assumptions) 3 

Figure  4.  Pilgrim  Cost  Components  (BECO  Assumptions) 4 

Figure  5.  Pilgrim  Annual  Generation  Costs  (Alternative) 6 

Figure  6.  Pilgrim  Total  Costs  (Alternative) 7 

Figure  7.  Alternative  Project  Fuels 9 

Figure  8.  Pilgrim  vs.  Alternative  Annual  Generation  Costs 9 

Figure  9.  Pilgrim  vs.  Replacement  Power  Costs  (BECO  Assumptions) 10 

Figure  10.  Pilgrim  Operation  vs.  Retirement  (BECO  Assumploins) 11 

Figure  11.  Pilgrim  Operation  vs.  Retirement  (Present  Value) 13 

Figure  12.  Cumulative  Savings  from  Retiring  Pilgrim 14 

Figure  13.  Savings  from  Retiring  Pilgrim  (Sensitivity  to  Sunk  Costs) 14 

Figure  14.  National  Average  Capital  Additions 23 

Figure  15.  Pilgrim  &  National  Average  Capital  Additions 23 

Figure  16.  Capital  Additions  Projections 24 

Figure  17.  Cumulative  Savings  from  Retiring  Pilgrim  (Sensitivity  to  Capital  Additions) 24 

Figure  18.  Pilgrim  vs.  National  Average  O&M  Costs 25 

Figure  19.  O&M  Cost  Projections 26 

Figure  20.  Cumulative  Savings  From  Retiring  Pilgrim  (Sensitivity  to  O&M  Costs) 26 

Figure  21.  Pilgrim  vs.  National  Average  Capacity  Factor 27 

Figure  22.  Capacity  Factor  Projections 27 

Figtire  23.  Cumulative  Savings  from  Retiring  Pilgrim  (Sensitivity  to  Capacity  Factor) 28 


LIST  OF  TABLES 


Table  1.  Alternative  Assumptions  Used  in  MASSPIRG  Projections 12 

Table  2.  Additional  Conservatisms  in  All  Scenarios 12 

Table  3.  Savings  to  Ratepayers  From  Retiring  Pilgrim 13 

Table  4.  Oldest  U.S.  Operating  Nuclear  Reactors 31 

Table  5.  Retired  U.S.  Reactors 31 


285 


EXECUTIVE  SUMMARY 


This  study  examines  the  costs  and 
benefits  of  permanently  closing  the 
Pilgrim  nuclear  plant,  and  replacing  it 
with  alternatives  that  are  currently  avail- 
able to  Boston  Edison  (BECO).  Using 
conservative  assumptions  which  are  likely 
to  underestimate  Pilgrim's  costs,  and  to 
overestimate  the  cost  of  alternatives, 
MASSPIRG  has  found  that: 

1.  Utility  customers  would  save  at  least 
$1.5  billion  (present  value)  over  the  next 
25  years  by  closing  Pilgrim,  if  future 
Pilgrim  costs  were  to  follow  historical 
trends  for  the  plant.  These  savings  would 
occur  even  if  ratepayers  had  to  pay  for  the 
full  utility  investment  in  the  plant  to  date, 
including  the  same  profit  the  companies 
would  have  earned  if  the  plant  had 
operated. 

2.  K  trends  at  Pilgrim  improved  to  the 
most  optimistic  levels  that  could 
reasonably  be  hoped  for,  utility  customers 
would  still  save  money  by  retiring  Pilgrim, 
even  if  they  had  to  pay  for  the  full  sunk  in- 
vestment in  the  plant. 

3.  Even  under  Edison's  own  assump- 
tions, which  are  unrealistic,  ratepayers 
would  likely  benefit  from  Pilgrim  retire- 
ment, if  the  Massachusetts  Department  of 
Public  Utilities  required  utility  customers 
and  investors  to  share  the  cost  of  past  in- 
vestment in  Pilgrim  according  to  tradition- 
al regulatory  practice. 

This  study  starts  with  the  same  figures 
and  uses  the  same  methods  of  analysis 
employed  by  BECO  in  a  recent  presenta- 
tion to  the  Massachusetts  Executive  Of- 
fice of  Energy  Resources  (EOER).  The 


utility's  assumptions  about  fumre 
Pilgrim  performance  and  major  costs 
are  compared  to  past  performance  and 
cost  trends  at  Pilgrim  and  other  U.S. 
nuclear  plants,  and  alternative  assump- 
tions and  cost  projections  are 
developed. 

In  order  to  err  on  the  side  of  underes- 
timating Pilgrim  costs,  MASSPIRG 
uses  a  number  of  unrealistically  low 
Edison  estimates  in  all  projections.  The 
costs  of  nuclear  fuel,  nuclear  waste  dis- 
posal and  of  dismantling  Pilgrim  at  the 
end  of  its  operating  life  are  unchanged 
from  BECO  projections.  It  is  assumed 
that  the  15-year-old  Pilgrim  plant  could 
operate  for  a  total  of  40  years,  although 
no  nuclear  plant  has  operated  for 
longer  than  26  years.  To  be  as  favorable 
to  Pilgrim  as  possible,  MASSPIRG  also 
assumes  that  the  cost  of  replacement 
parts  and  safety  upgrades  will  level  off, 
and  that  Pilgrim  performance  will  not 
deteriorate  with  age. 

Replacement  power  for  Pilgrim  is 
readily  available  from  at  least  two  sour- 
ces. First,  Pilgrim's  owners  could 
"mine"  electricity  that  is  currently 
wasted  by  inefficient  lighting,  applian- 
ces, and  other  electrical  equipment.  A 
report  to  Edison's  Board  of  Directors 
indicated  the  potential  to  reduce  the 
utility's  electric  demand  by  1,000 
megawatts  (Mw),  at  an  average  cost  of 
less  than  two  cents  per  kilowatt  hour 
saved.  Second,  Pilgrim's  owners  could 
purcha.se  electricity  from  small  power 
producers  and  cogenerators.  Indepen- 
dent power  producers  have  bid  to  supp- 


286 


ly  Boston  Edison  with  1,848  Mw  by  19*^2. 
Pilgrim  capacity  is  670  Mw. 

While  some  of  the  independent 
facilities  have  environmental  problems, 
the  combined  potential  of  the  efficiency 
improvements  and  independent  power 
producers  could  replace  Pilgrim  and  meet 
Edison's  projected  demand  growth  with 
over  1,000  Mw  to  spare.  In  order  to  over- 
estimate  the  cost  of  replacing  Pilgrim,  it  is 
assumed  that  all  the  efficieno,'  savings  go 
to  displace  demand  growth,  with  the  cost 
of  power  to  replace  Pilgrim  based  on  a 
range  of  bids  from  cogeneration  and 
small  power  facilities. 

The  table  and  figure  below  summarize 
the  savings  to  ratepayers  from  retiring 
Pilgrim  under  various  assumptions.  The 
"Pilgrim  Optimistic  Case"  (most  favorable 
to  Pilgrim)  combines  the  lowest 

PILGRIM  OPERATION  VS.  RETIREMENT 
Present  Value  (Billjon_1937j)_ 


reasonanie  level  of  Piigriin  costs  wnii 
the  highest  le^ei  of  replacenient  powe^ 
costs.  The  "National  Treno  Case"  as- 
sumes that  the  rate  of  escalating  costs 
at  pilgrim  improves  to  the  level  o*"  the 
average  nuclear  plant  with  Pilgrim's 
characteristics  (age,  type,  location, 
etc.  i.  anu  a  moderate  ieve!  of  replace 
ment  power  costs.  Tne  "Pilgrim  f  hston- 
cal  Trend  Case"  assumes  that  Pilgrim 
cosl.^  coniiaue  to  escala'e  at  theii  his- 
toric rat  3S,  and  assuines  the  lowest 
level  of  replacen.ent  powei  costs. 

All  cases  show  savinf.?  to  ratepayers 
from  retiring  Pilgrim.  M.^ SSPIRG 
therefore  recommends  that  the  Pilgrim 
njan'  b'  ^erf^''.r°'-*'^'  c'osed.  The 
Department  of  Public  Utilities  shou'.d 
allow  no  recovery  of  any  f-  ture  utility 
investment  'u\  the  plant. 


^1 


Repl.  Power 


fptiffiistftr- 
S'^utdcwn 


Sunk 


SAVINGS  TO  RATEPA^'ERS  FROM  RETirJNG  F O.GRIM 


pilgrim  Historical 
Trend  Case 

National 
Trend  Case 

Pilgrim  Optimistic 
Case 

BECO 


Ratepayei-   Pa% 
SunkCt'ts 

$1.56bUriOn 
$813  million 
$49  million 
-$()lt  millii'f 


I  «  ?stors  Pay  ; 
Sunk  Costs     j 

$2.28  biUiou 
Sl.54  billion 
$773  jiiillior! 
$168  miiiiori 


287 


1.  Introduction  -  Nuclear  Costs  and  Cancellations 


The  Pilgrim  nuclear  power  plant,  in 
Plymouth,  Massachusetts,  is  the  focus  of 
intense  controversy  over  health  and  safety 
issues.  (See,  for  example,  No  Exit:  The 
MASSPIRG  Sun'ey  of  Pilgrim  Evacuation 
Planning,  September  1987.)  Relatively  lit- 
tle attention,  however,  has  been  paid  to 
the  increasing  cost  of  operating  the 
Pilgrim  plant. 

When  Pilgrim  was  first  turned  on  in 
late  1972,  it  appeared  to  be  a  relatively  in- 
expensive source  of  electric  power.  Built 
for  $232  million,  Pilgrim's  construction 
cost  about  three  tirnes  as  much  per 
idlowatt  of  capacity  as  an  oil-  fired  plant. 
But  uranium  fuel  was  so  much  cheaper 
than  oil,  especially  after  the  oil  embargo 
of  1973,  that  the  total  cost  of  owning  and 
operating  the  nuclear  plant  was  less. 

It  is  worth  noting  that  some  nuclear 
costs  —  such  as  for  research  and  develop- 
ment, fuel  processing  and  insurance  — 
were  heavily  subsidized  by  federal  tax  dol- 
lars. The  Price-Anderson  Act,  passed  by 
the  U.S.  Congress  in  1957,  limited  in- 
dustry liability  for  nuclear  accidents, 
thereby  relieving  it  of  having  to  consider 
fully  the  economic  risks  of  nuclear  genera- 
tion. Other  costs  ~  fo''  disposing  of 
nuclear  wastes  and  dismantling  the  plant 


at  the  end  of  its  operating  hfe  (decom- 
missioning) --  could  not  be  reliably  es- 
timated then  or  now,  since  the  required 
technologies  still  have  not  been 
demonstrated." 

During  the  1970s,  the  co.st  of  build- 
ing new  nuclear  plants  escalated 
dramatically.  Nuclear  construction 
costs  increased  by  over  twice  the  infla- 
tion rate,  and  nearly  twice  as  fast  as  the 
f"  St  cf  bi  i!  Jin;^  coi.i-fircd  pLnts. 
Major  causes  of  the  increases  included 
technical  problems  that  were  identified 
as  nuclear  plants  gained  operating  ex- 
perience, new  safety  regulations  im- 
posed by  the  Nuclear  Regulatory 
Commission  (NRC),  and  management 
failures  to  anticipate  and  respond  ade- 
quately to  these  pressures. 

As  a  result  of  increasing  nuclear  con- 
struction costs,  and  a  drop  in  electricity 
demand  growth,  many  orders  for 
nuclear  plants  were  canceled  in  the 
1970s  and  1980s.  Over  110  nuclear 
plants  -  almost  half  of  the  total  num- 
ber that  utilities  had  ordered  -  were 
canceled  in  various  stages  of  construc- 
tion, including  a  second  unit  planned 
for  the  Pilgrim  site." 


'Power  plant  capacity  is  measured  in  watts.  A  kilowatt  (Kw)  is  equal  to  1,000  watts,  enough  power  to  light 
ten  100-watt  light  bulbs.  A  megawatt  (Mw)  equals  one  million  watts  or  1,000  kilowatts.  An  amount  of 
electricity  generated  over  a  period  of  time  is  measured  in  kilowatt  hours.  A  one  megawatt  plant  operating 
at  full  capacity  for  1  hour  would  produce  1,000  kilowatt  hours  (Kwh)  of  electricity.  Pilgrim's  capacity  is 
670  MW,  of  which  Boston  Edisoa  owns  74.27  p^rceat.  OthLi  owi.crs  arc.  Commonwealth  Electric   -  11 
percent.  Eastern  Utilities  -  10.5  percent,  Massachusetts  Municipal  Wholesale  Electric  -  3.73  percent, 
and  Newport  Electric  -  .5  percent.  For  simplicity,  Pilgrim  v-ill  be  treated  in  this  report  as  it  it  were  entire- 
ly owned  by  Boston  Edison. 


288 


The  same  factors  that  caused  construc- 
tion costs  to  skyrocket  for  new  nuclear 
plants  have  also  increased  the  costs  of 
older  plants.  Large  expenses  have  been  re- 
quired for  replacement  equipment  and 
safety  improvements,  called  "capital  addi- 
tions," and  for  major  repairs.  In  addition 
to  work  needed  to  bring  older  plants  up 
to  new  safety  standards,  many  nuclear 
parts  and  systems  have  worn  out  sooner 
than  expected.  ^  For  the  U.S.  nuclear  in- 
dustry as  a  whole,  capital  additions  in- 
creased by  an  average  of  13  percent  a 
year,  after  adjusting  for  inflation,  between 
1970  and  1986.  Operation  and  main- 
tenance costs  increased  by  an  average  of 
over  11  percent  a  year,  after  inflation, 
during  the  same  period.  In  addition,  the 
majority  of  nuclear  plants  failed  to  per- 
form as  reliably  as  their  owners  expected, 
experiencing  many  more  shutdov.'ns  than 
other  types  of  power  plants. 

As  a  result  of  these  increasing  capital 
and  operating  costs,  some  utilities  have 
begun  to  take  a  hard  look  at  the  cost  of 
continuing  to  operate  nuclear  plants.  In 
March,  1986,  the  Washington  Public 
Power  Supply  System  (WPPSS)  tem- 
porarily closed  its  two-year-old  operating 
reactor  because  it  was  more  expensive  to 
operate  than  oil  or  gas-fired  plants.  In 
May,  1987,  the  Dairyland  Power  Coopera- 
tive, in  Wisconsin,  permanently  shut 
down  its  18-year-old  LaCrosse  nuclear 
plant  because  it  was  no  longer  competi- 
tive with  alternatives. 

The  Pilgrim  nuclear  plant  has  been 
subject  to  the  same  cost  trends  as  other 
nuclear  plants.  In  fact,  between  1980  and 
1985,  Pilgrim  had  the  second  most  expen- 
sive capital  additions  per  kilowatt  of  any 
nuclear  U.S.  power  plant,  .ind  has  be- 
come one  of  the  most  expensive  nuclear 
plants  in  the  country.^''  By  the  end  of 
1987,  Boston  Edison  (BECO)  will  have 


sunk  S614  million  into  Pilgrim  above  its 
$232  million  original  cost,  bringing  the 
total  investment  in  the  plant  to  $846 
million  (Figure  1).  Even  after  adjusting 
for  inflation,  Boston  Edison  has  spent 
40  percent  more  for  replacement  and 
new  parts  for  Pilgrim  than  it  initially 
spent  building  the  plant. 

Largely  as  a  result  of  these  capital 
additions,  Boston  Edison's  own  es- 
timates show  that  in  1988,  electricity 

Figure  1 

PILGRIM  CAPITAL  COST 
QQQ M[llion^^Nomina[) 


Year 


from  Pilgrim  will  cost  6.53  cents  per 
Kwh,  almost  twice  as  much  as  power 
from  oil-fired  plants,  at  a  cost  of  3.34 
cents  per  Kwh  (Figure  2). 

BECO  also  recognizes  that  con- 
tinued Pilgrim  operation  will  require 
ongoing  capital  additions.  Edison  es- 
timates that  keeping  Pilgrim  running 
will  require  another  $1.4  billion  invest- 
ment in  capital  additions  over  the  25 
years  it  estimates  for  Pilgrim's  remain- 
ing life.  Pilgrim's  total  capital  cost 
would  then  equal  over  $2.25  billion  dol- 
lars -  almost  ten  times  the  initial  con- 
struction cost  of  the  plant  (Figure  3). 
Moreover,  independent  estimates  dis- 
cussed in  the  following  chapters  of  this 


289 


0.07 


Figure  2 

ELECTRICITY  GENERATION  COST  -- 1988 
SperKWh 


report  indicate  that  capital  additions  and 
other  costs  are  actually  likely  to  exceed 
BECO  estimates.  These  escalating  costs 
require  serious  consideration  of  whether 
continued  investment  in  and  operation  of 
Pilgrim  is  economical. 

In  April,  1986,  the  Pilgrim  plant  ex- 
perienced two  "unexplainable  automatic 
shutdowns,"  or  "scrams."  The  NRC  or- 
dered the  plant  to  remain  closed  until 
serious  problems  with  Pilgrim  and  its 


management  are  resolved.  During  this 
time,  Boston  Edison  has  chosen  to 
make  major  upgrades  in  the  Pilgrim 
plant  ~  budgeting  over  $150  million  in 
capital  additions  and  nearly  $100  mil- 
lion in  maintenance  costs  in  1987  -  to 
return  the  Pilgrim  plant  to  service.  This 
study  looks  at  whether  it  makes  more 
economic  sense  to  retire  Pilgrim  than 
to  continue  investing  hundreds  of  mil- 
lions of  dollars  in  it.  Chapter  2  looks  at 
Boston  Edison's  projections  of  Pilgrim 
costs,  compares  BECO  assumptions 
about  nuclear  cost  trends  to  the  histori- 
cal trends  at  Pilgrim  and  other  nuclear 
plants  around  the  country,  and 
develops  more  realistic  estimates  of  fu- 
*ure  Pilgrim  costs.  Chapter  3  examines 
the  cost  of  retiring  the  Pilgrim  plant 
and  replacing  it  with  alternatives  cur- 
rently available  to  Boston  Edison. 
Chapter  4  summarizes  the  report's 
overall  findings  and  presents 
MASSPIRG's  recommendations. 


2.4 
2.2 

2 
1.8  _ 
1.6  _ 
1.4 
1.2 

1 
0.8 
0.6  4 
0.4 

0.2      i-S-B-&<5'-»-^'^ 


Figure  3 

PILGRIM  CAPITAL  COST  PROJECTION 

BECO  Assumptions  -  Billion  $  (Nominal) 


cr-- 


^' 


.Ji 


ja^ 


i»72       iy// 


"  ^ra82 TgST-      ■    1i»2^ 

Year 


Pilgrim  Historical 


Tggy 2002 2007—201 2 

_     BECO  Projection 


290 


2.  The  High  Cost  of  Operating  Pilgrim 


A.  Boston  Edison  projections 


In  May,  1987,  Boston  Edison 
developed  projections  of  Pilgrim's  future 
costs  in  response  to  a  request  by  the  Mas- 
sachusetts Executive  Office  of  Energy 
Resources  (EOER).  Edison's  projections 
were  also  sent  to  the  Office  of  the  Attor- 
ney General,  the  Department  of  Public 
Utilities,  and  upon  request,  to 
MASSPIRG. 


BECO  projects  that  the  cost  of 
electricity  from  the  Pilgrim  plant  will  in- 

Flgure  4 

PILGRIM  COST  COMPONENTS 


crease  from  6.53  cents  per  kilowatt 
hour  (Kwh)  in  1988  to  16.76  cents  per 
Kwli  in  2012  (Figure  4),  primarily  as 
the  result  of  inflation.  Another  way  of 
looking  at  the  cost  of  Pilgrim  is  to  add 
up  the  total  bill  to  ratepayers  for  the 
plant's  costs  over  the  remainder  of  its 
expected  life.  The  "present  value"  of 
BECO's  estimate  of  future  Pilgrim 
costs  (discounting  future  dollars  at  the 
10.55  nercenf  annual  rate  Edison  uses 
to  account  for  the  declining  value  of 
money  over  time)  is  $3.3  billion  in  1987 
dollars. 


BECO  Assumptions  ~  $  per  Kwh 


(See  next  page  for  explanation.) 


291 


HOW  Pttgrim  Costs  Are  Calculated  ! 

The  grsph  on  the  opposite  p^e  sbov/s  how  much  Boston  Edisoa  expects  to  charge  its  cuslomeis  each 
year  for  ctectridty  from  Rlgripi,  based  on  the  standard  ruks  of  utility  regulation.  Electric  companies   ■ 
wrc  allowed  to  recover  most  operating  and  fuel  expenses  directly  in  rates  as  they  are  incurred  each 
year.  Utility  investment  in  ms^or  plant  and  equiproeni  is  recovered  over  the  operating  life  of  the  plant ; 
tiiroi^  depredation  charges.  Utilities  arc  aUo  allowed  to  charge  customers  for  their  financing  costs,  • 
bdttdEiiig  a  profit  on  their  iitvesimetH. 

Tttebottamsectiooof  each  bar  isi  the  graph  shows  the  financing  charges,  or  {sbim,  that  BECO  ex- 
pects to  earn  on.  its  PUgrnB  investiaBiit.  The  return  consists  of  interest  payments  on  debt  borrowed  to 
finaBce  ^I^ib,  and  the  profits  BECO  expects  regulators  to  allow  it  to  earn  on  its  iDvestnrent  in  the 
plant  Ute  neM  area  up  represents  d6prf^:iatif)n  of  BECX)'s  Pllgrtm  investment.  The  third  area  from 
thoboUotttdcpicts  nperation  and  nminhMiance  (0&M>  charges,  which  include  labor  and  direct 
i^perptia^  ei^nscs.  Above  O&M  are  the  costs  for  nuclear  £ueI,  inchiding  current  estimates  of  waste 
(Ssposal  wste-  The  next  area  of  the  graph  shows  how  much  money  is  collected  to  pay  for  dscijinnui:  . 
jjflniag  the  plant  at  the  end  of  its  operating  life.  The  top  area  indicates  mwcftllanenns  expenses,  such 
as  lnsow»c<^  and  local  property  taxes,       , 

BECO  expects  to  cam  a  14:4  perceai  rate  orreitun  on  its  PHgrirt  mvestmeni.  About  38  percent  of 
tbat  ammmf  is  paid  to  th«  federal  government  for  income  taxes.  Every  billion  dollars  invested  in 
Pflgtimtfaus  translates  into  ^44  million  in  charges  per  year  in  rates.  Each  year,  1/40  of  the  investment 
in  l4]gtkD.is^  charged  to  ratepayers  for  depreciation,  and  that  amount  is  subtracted  trom  the  next 
year's  'rate  base,*  an  account  In  the  ntifity's  books  representing  the  amount  of  investment  on  which 
the  nlility  can  earn  a  return. .  The  current  fise  for  waste  disposal  assessed  by  the  Etepartment  of  Ener- 
gy is  one-tenth  of  a  cent  per  KWh.  Decommissiomng  cost  charges  are  calcnlatsd  to  accumulate  the 
$325  nuBiOR  (in  1^6  doQar^  Edison  estimates  will  be  necessary  to  dismantle  the  nudear  plant  b  the 
year  2^112.  Property  taxes  average  abont  1.8  percent  of  the  %'Blue  of  the  plant  in  rate  base.  Insuraitce 
costs  incTBWc  over  time  from  $5-15  miUion  a  year. 

The  cost  per  kilowan  houi  is  i^dcidated  by  dividing  the  total  annual  cost  by  the  number  of  Kwh 
generated  per  year.  KWh  j>er )%» t«  afunction  of  capacity  factor  (see  Chapter  3,  Section  B)  multi- 
pMed  by37£Q  hoars  per  year  tiates  the  670,000  kilowau  sixc  of  the  plant,  Edison  assumes  a  70  percent  j 
capacity  factor  fot  future  Klgpm  operation.  i 


But  based  on  historic  iiucl^r  cost 
trends,  Edison  is  greatly  underestimating 
Pilgrim  costs.  Projecting  the  total  cost  of 
electricity  from  a  power  plant  involves 
making  nimierous  assumptions  about 
various  cost  components,  as  well  as  the 
overall  operating  performance  of  the 
plant.  Three  assumptions  irt  particular 
dominate  the  final  results:  the  rate  of  capi- 
tal additions,  oi>eration  and  maintenance 
(O&M)  expenses,  and  the  amount  of  time 
the  plant  can  be  expected  to  operate 
(capacity  factor). 


B.  MASSPIRG  projections 


MASSPIRG  has  compared  Edison 
assumptions  in  each  of  these  areas  to 
actual  performance  and  cost  trends  at 
Pilgrim  and  other  nuclear  plants 
around  the  country.  The  sf>ecific  results 
of  these  comparisons  are  presented  in 
Appendix  B.  In  general,  Edison  projec- 
tions assume  that  the  past  performance 
of  Pilgrim  and  other  nuclear  plants 
provide  no  guide  to  future  costs  Consi.'?- 
tent  historical  trends  -  both  at  Pilgrim 
and  at  nuclear  plants  around  the 


292 


country  —  are  assumed  to  immediately 
stop. 

O&M  costs,  which  have  increased  na- 
tionally by  1 1.4  per  year,  after  adjusting 
for  inflation,  and  by  13.8  percent  annually 
at  Pilgrim,  are  projected  to  increase  at 
only  0.5  percent  per  year  henceforth. 
Capital  additions,  which  have  escalated 
nationally  at  13  percent  per  year  after  in- 
flation, and  much  faster  at  Pilgrim,  are 
also  forecast  by  Edison  to  increase  by  0.5 
percent  per  year  in  the  future.  Despite 
the  fact  that  Pilgrim  has  had  a  lifetime 
capacity  factor  of  only  50  percent,  and  the 
national  average  for  nuclear  plants  is  60 
percent,  Edison  predicts  that  Pilgrim  will 
average  a  70  percent  capacity  factor  in  the 
future. 

Nuclear  utilities  around  the  country 
have  been  making  similar  assumptions  for 
many  years.  Each  year,  the  utilities 
project  that  nuclear  costs  will  freeze  at 
then-current  levels.  Instead,  real  costs 
have  continued  to  rise.  The  basic  forces 
that  have  run  up  nuclear  costs  in  the  past 
will  continue  to  increase  costs  in  the  fu- 
ture. These  factors  include  technical 
problems  discovered  as  nuclear  plants 
gain  more  operating  experience,  un- 


resolved generic  nuclear  safety  issues, 
the  aging  of  reactor  parts,  and  the 
potential  for  both  small  and  large 
nuclear  accidents  to  create  new 
regulatory  requirements.     (See  Appen- 
dix C  for  additional  discussion.) 

It  is  therefore  important  to  examine 
more  realistic  assumptions  for  nuclear 
costs.  MASSPIRG  looks  at  three  alter- 
native assumptions  for  each  major 
nuclear  cost  component.  In  a  "Pilgrim 
Historical  Case,"  future  costs  are  as- 
sumed to  continue  to  escalate  in  line 
with  historical  trends  for  the  Pilgrim 
plant.  In  a  "National  Trend  Case," 
Pilgrim  cost  trends  are  predicted  to  im- 
orove  to  match  those  of  the  average 
plant  having  Pilgrim's  characteristics. 
For  a  "Pilgrim  Optimistic  Case,"  it  is  as- 
sumed that  future  Pilgrim  co.sts  will  im- 
prove to  a  level  substantially  better 
than  would  be  expected  based  on  either 
Pilgrim  or  national  trends. 

The  detailed  basis  of  MASSPIRG's 
alternative  projections  are  presented  in 
Appendix  B.  Figures  5  and  6  Olustrate 
the  effect  of  the  revised  assumptions  on 
the  aimual  cost  per  Kwh  and  on  the 
total  present  value  of  Pilgrim  costs  to 


Figure  5 
PILGRIM  ANNUAL  GENERATION  COSTS 
Alternative  Scenario  Analysis 


BECO 


Opt  ^      Nat^frend 


-2008—- 
Pila  Trend 


293 


Figure  6 
RANGE  OF  PfLGRIM  TOTAL  COSTS 
Present  Value  (Billion  1987  $) 


0-^il^^ 


Trench 


?<fl 


k53 


— -Natiofrat  Trer 


ratepayers,  respectively. 

All  three  MASSPIRG  cases  share  a 
number  of  extremely  conservative  assump- 
tions. In  general,  nuclear  costs  are  as- 
sumed to  be  increasing  according  to 
linear  trends  (i.e..  a  constant  number  of 
dollars  per  year,  after  adjusting  for  infla- 
tion) rather  than  according  to  exponential 
trends  (i.e.,  a  constant  percentage  in- 
crease per  year,  after  inflation).  The  trend 
of  increasing  capital  additions  is  still  as- 
sumed to  level  off  in  a  few  years,  despite 
evidence  that  it  may  actually  be  accelerat- 
ing. Plant  performance  is  not  assumed  to 
deteriorate  with  age,  despite  evidence  of 
declining  capacity  factors,  particularly  at 
salt-water-cooled  plants  like  Pilgrim. 

For  simplicity,  and  to  be  as  favorable 
to  Pilgrim  as  possible,  this  report  also 
adopts  a  number  of  other  Edison  assump- 
tions which  are  biased  in  favor  of  Pilgrim. 
The  Pilgrim  plant  is  assumed  to  be 
operable  until  the  year  2012  --  a  total  of 
40  years  from  when  it  entered  service. 
The  oldest  commercial  nuclear  plant  has 


^1 


^Opttmtsticr- 


Pilgrim 

operated  for  only  26  years,  and  14  reac- 
tors have  been  retired  atter  less  than  20 
years  of  operation.  Pilgrim's  operating 
license  currently  expires  in  the  year 
2008.  and  would  have  to  be  extended 
by  the  NRC  in  order  for  the  plant  to 
operate  until  2012. 

Real  nuclear  fuel  costs  are  assumed  to 
remain  stable,  even  though  ap- 
proximately half  of  the  uranium  used  in 
domestic  nuclear  plants  is  imported, 
much  of  it  from  politically  unstable 
countries  such  as  South  Africa.^^ 
BECO's  estimates  for  nuclear  waste  dis- 
posal and  for  dismantling  the  radioac- 
tive plant  are  used,  despite  the  fact  that 
the  necessary  technologies  have  not  yet 
been  demonstrated  and  there  is  there- 
fore enormous  uncertainty  around  es- 
timating these  costs.  And  it  is  assumed 
that  no  serious  nuclear  accidents  occur 
at  Pilgrim  or  at  any  other  U.S.  nuclear 
plant.  The  conservative  nature  of  these 
assumptions  is  discussed  in  more  detail 
in  Appendix  C. 


294 


3.  Economic  Benefits  of  Retiring  Pilgrim 


There  are  three  categories  of  potential 
costs  to  ratepayers  for  retiring  Pilgrim  at 
this  time.  First,  there  is  the  cost  of  re- 
placement power.  Second,  there  are  costs 
to  shut  the  plant  down  and  decommission 
it,  which  must  be  paid  whether  the  plant 
is  retired  now  or  later.  Third,  there  is  the 
potential  cost  of  paying  for  past  invest- 
ment in  the  plant.  Each  cost  will  be  con- 
sidered separately. 

A.  Replacement  power 


The  main  cost  of  retiring  Pilgrim  would 
be  to  replace  the  electricity  produced  by 
the  nuclear  plant.  As  demonstrated  in  the 
recent  New  England  Energy  Policy  Coun- 
cil study.  Power  to  Spare,  the  least  expen- 
sive means  of  obtaining  new  power 
supplies  is  to  "mine"  the  electricity  that  is 
now  wasted  by  inefficient  lighting,  ap- 
pliances, and  other  electrical  equipment 
in  our  offices,  factories  and  homes. 
Utilities  around  the  United  States  have 
found  that  they  can  flnance  efficiency  im- 
provements for  their  customers  at  an 
average  cost  of  less  than  two  cents  per 
Kwh.     That  is  less  expensive  than  opera- 
tion and  maintenance  costs  alone  at 
Pilgrim.  A  report  to  Boston  Edison's 
Board  of  Directors  in  March,  1987,  found 
that  cost-effective  efficiency  improve- 
ments could  reduce  electric  demand  in 
Boston  Edison's  service  territory  by  as 
much  as  1,000  Mw  over  the  next  15 

14 

years. 


Another  readily  available  source  of 
replacement  power  for  Pilgrim  would 
be  the  purchase,  of  electricity  from  new 
plants  built  and  owned  by  independent 
small  power  producers,  generally 
referred  to  as  "Qualifying  Facilities"  or 
"QFs."  Since  the  pas'.age  of  the  federal 
Public  Utility  Regulator)'  Policies  Act 
(PURPA)  of  1978,  which  required 
utilities  to  purchase  power  from  inde- 
pendent producers  at  fair  prices,  there 
has  been  a  rapid  increase  in  the 
development  of  such  facilities 
throughout  the  country. 

In  January,  1987,  in  response  to 
rules  enacted  by  the  Massachusetts 
Department  of  Public  Utilities,  Boston 
Edison  sent  a  Request  for  Proposals  to 
potential  developers  to  supply  200 
megawatts  (Mw)  of  Edison's  power 
needs  by  1992.  The  utility's  projection 
of  future  oil  costs  was  set  as  the  ceiling 
price  for  acceptable  offers.  In  June 
Edison  received  bids  from  61  projects, 
representing  a  total  of  1848  Mw.  The 
number  of  proposals  received  was  well 
above  the  utility's  expectations.  In  fact, 
in  its  April  1987  forecast,  the  New 
England  Power  Pool  h?d  projected  that 
only  1391  Mw  of  independent  power 
would  be  avaibble  for  the  ertire  region 
by  the  year  2002. 

The  majority  of  the  proposals  were 

for  co3;r.';:ali:.;  TacUtics  -  v.liioh 
produce  useful  heat  and  electricity  in 
the  same  process  -  and  other  small 
power  facilities  using  a  variety  of  fuels 


295 


Figure  7 


BECO-8  RFP«1:  TOTAI,  MT^  BID  BY  FUEL  TlTS 
iB»-.»2  u*  -soy  61  ^to^tcrz 


Oth«r  (1  S.eX)^/-''^ 

^^        Natural 

/ 

|^:'^-vvv'  ;^  Ga«  (31.'?;) 

Wood  *  Peat  (3.4J!)    ^S;>-^,^  ■ 

^^^^^^^^^^ 

■i^:.-^',    .>^'%i.^ 

^^^^^^^5= 

=^:i;i-  ;.^^•-^v>3 

R«tuae  (10. BX)  i&r^^^^ 

T^-^^f 

"^ir  iH.iii;;'"' 

-:                       ^-  Wnd  (O.St) 

/' 

X;'!^''' 

,,:,.      •   v/ 

Coal  (35.3X) 

(Figure  7).  Over  240  Mw  would  be 
produced  using  renewable  energy  sour- 
ces, such  as  biomass,  wind  or  hydropower. 

Some  of  the  projects,  particularly  the 
200  Mw  of  plants  which  would  bum 
refuse  as  fuel,  may  present  emaronmental 
problems.  MASSPIRG  does  not  neces- 
sarily endorse  all  of  the  proposed  QFs. 
However,  the  combination  of  energy  ef- 
ficiency improvements  and  the  large  num- 
ber of  small  power  and  cogeneration 
projects  provides  a  more  than  adequate 
pool  of  potential  replacement  power  for 
Pilgrim.  The  combined  potential  of  ener- 
gy efficiency  improvements  and  inde- 
pendent power  projects  exceeds  Edison's 
share  of  the  Pilgrim  plant  and  its 


forecast  of  power  needed  to  meet  in- 
creased demand  through  the  year  2012 
by  over  1,100  Mw.^^ 

Nine  QF  projects,  representing  350 
Mw,  were  selected  by  Edison  as  an  ini- 
tial "Award  Group"  for  final  contract 
negotiation.  The  average  Award  Group 
bid  was  sig:niricantly  below  the  price  of 
Pilgrim-generated  electricity,  even 
using  all  of  Boston  Edison's  Pilgrim 
cost  assumptions  (Figure  8). 

If  Pilgrim  were  lo  be  replaced,  there 
v'ould  be  a  second  round  of  bidding.  It 
is  quite  likely  that  many  bids  would  be 
lowered  given  the  large,  and  previously 
unknown,  surplus  of  potential  supply 
o^er  ^oiouii's  demand.  In  the  first 
round,  potential  developers  were  bid- 
ding primarily  against  BECO's  extreme- 
ly high  projection  of  oil  price  increases. 
The  utility  forecasts  oil  prices  to  in- 
crease at  an  average  rate  of  over  ten 
percent  a  year,  approximately  five  per- 
cent above  the  assumed  inflation  rate 
between  now  and  the  year  2012.  Oil 
prices  would  increase  from  their  cur- 
rent $20  per  barrel  to  $166  per  barrel 
in  2012,  or  to  over  $53  a  barrel  in  1987 
dollars  adjusted  for  inflation. 


Figure  8 
PILGRIIVI  VS.  QF  ANNUAL  GENERATION  COSTS 
BECO  Projection  -  $  per  Kwti 


18^ 
8:8? 

0.00 


2123 


Pilgrim 


Year 


Award  Group 


296 


To  be  as  favorable  to  Pilgrim  as  pos- 
sible, however,  the  Award  Group  bids  are 
assumed  by  MASSPIRG  to  represent  the 
low  end  of  a  range  of  replacement  power 
costs.  Efficiency  savings  are  assumed  to 
be  used  entirely  to  displace  demand 
growth  rather  than  to  replace  Pilgrim. 
The  average  bid  of  the  next  block  of  740 
Mw  is  used  as  a  middle  estimate  of 
Pilgrim  replacement  costs.  And  the 
average  bid  of  all  the  non- Award  Group 
projects  is  adopted  as  a  high  estimate  of 
replacement  power  costs. 

Using  BECO's  assumption  of  a  70  per- 
cent capacity  factor  for  Pilgrim,  the  total 
present  value  of  replacement  power 
needed  would  range  from  $2.5  billion, 
based  on  the  Award  Group,  to  $2.9  bil- 
lion, based  on  the  average  non-Award 
Group  bid,  through  the  year  2012  (Figure 
9).  If  one  assumes  lower  Pilgrim  capacitv' 
factors,  replacement  power  would  cost 
even  less. 

All  the  proposed  QFs  have  projected 
in-service  dates  before  1992,  with  400  Mw 
expected  to  be  available  by  the  end  of 
1990.  For  this  study,  it  is  assumed  that  all 
QFs  begin  operation  in  1992.  Until  that 
time,  replacement  power  costs  are  as- 
sumed to  equal  energy  costs  from  reserve 
oil-fired  plants,  plus  an  additional  charge 
by  the  New  England  Power  Pool  for 
providing  reserve  capacity.  The  1987  New 
England  Power  Pool  forecast  shows  a 
more  than  adequate  reserve  margin  of 
generating  capacity  through  1992  ~  even 
if  the  Pilgrim,  Seabrook,  and  Maine 
Yankee  plants  are  not  in  service. 

Reliance  on  non-utility  power  plants 
poses  certain  obvious  risks  to  a  utility, 
since  it  will  not  control  the  construction 
or  operation  of  the  QF  plants.  These  risks 
must  be  weighed  against  risks  associated 
with  Pilgrim,  however.  Pilgrim  could  be 
closed  by  federal  regulators  because  of  an 


accident  at  another  nuclear  plant,  as 
well  as  by  incidents  at  the  plant  iiself. 
The  diversity  of  the  QF  projects  makes 
it  more  likely  that  a  given  amount  of 
power  vn\]  be  available  at  all  times 

The  QF  contracts  also  provide  in- 
sulation from  important  financial  risks, 
since  they  are  based  on  payment  per 
Kwh  produced.  Their  private  owners 
thus  assume  the  risks  of  cost  overruns, 
poor  plant  performance  and 
profitability.  Most  of  the  Award  Group 
contracts  are  tied  to  the  Consumer 
Price  Index,  thereby  requiring  utility 
customers  to  bear  only  ihe  risk  of  unan- 

Figure  9 

PILGRIM  VS  RhPU\oEMENT  POWER  COSTS 


BECO  Assumptions  -  Billion  $ 


Pilgrim 


gj,  Replacement  power 


ticipated  general  inflation.  With 
Pilgrim,  however,  ratepayers  are  ex- 
pected to  bear  the  risk  of  all  cost  in- 
creases, including  inflation,  as  well  as 
the  risk  that  the  plant  does  not  perform 
as  reliably  as  expected. 

B.  Other  shutdown  costs 


A  decision  to  retire  Pilgrim  at  this 
time  would  involve  some  costs  in  addi- 
tion to  replacement  power.  Decommis- 
sioning costs,  for  instance,  would  stil! 
have  to  be  incurred  whenever  Pilgrim 


10 


297 


is  retired.  Actually,  since  the  cost  of 
decommissioning  is  likely  to  increase  as 
the  plant  becomes  more  radioactive,  it 
would  almost  certainly  be  cheaper  to 
decommission  it  earlier.  To  be  conserva- 
tive, however,  these  potential  savings  are 
not  considered  here.  Costs  that  would 
clearly  have  to  be  incurred  to  shut  Pilgrim 
down  must  be  added  to  the  cost  of  re- 
placement pwjwer  (or  subtracted  from  the 
cost  of  Pilgrim)  to  evaluate  the  economics 
of  early  retirement  of  the  plant. 

In  addition  to  direct  decommissioning 
costs  of  $126  million  in  1987  dollars, 
BECO  estimates  that  closing  Pilgrim  will 
require  additional  operation  and  main- 
tenance costs  over  a  five  year  decommis- 
sioning period.  The  total  decommis- 
sioning and  shutdown  costs  add  $206  mil- 
lion, in  addition  to  the  cost  of  replace- 
ment power,  to  the  present  value  cost  of 
retiring  Pilgrim.  Edison  fails  to  include 
these  costs  in  its  analysis  of  continuing  to 
operate  Pilgrim,  however,  presumably  be- 
cause the  costs  would  be  iacurred  after 
the  year  2012  -  the  last  year  BECO  looks 
at  In  the  MASSPIRG  scenarios,  the 
present  value  of  the  post-operation  costs 
are  included  in  both  early  and  late  retire- 
ment scenarios. 

C.  Sunk  costs. 


Another  potential  cost  to  retiring 
Pilgrim  is  repayment  of  the  money  that 
Edison  has  invested  in  the  plant  to  date  ~ 
generally  referred  to  as  "sunk  costs." 
POgrim  sunk  costs  will  total  $846  million 
by  the  end  of  1987.  In  its  analyses  of  the 
cost  of  retiring  Pilgrim,  BECO  effectively 
assumes  that  ratepayers  would  pay  for 
the  utility's  entire  investment  in  Pilgrim, 
along  with  the  same  rate  of  profit  it 
would  earn  if  the  plant  were  operated 
(Figure  10). 


Figure  10 

PILGRIM  OPERATION  VS  RETIREMENT 
4         BECO  Assumptions  -  Billion  $ 


23  Pll     ^  Rep.Pwr    K2I  Shutdwn  ^  Sunk 

In  addition  to  its  investment  in  the 
plant  itself,  Edison  also  includes  a  $50 
million  investment  in  an  inventory  of 
nuclear  fuel  and  $20  million  in 
materials  and  supplies  in  Pilgrim  sunk 
costs.  After  the  Pilgrim  2  unit  was  can- 
celed, however,  BECO  was  able  to 
recover  64  percent  of  its  investment  in 
nuclear  fuel  by  selling  it  to  other 
utilities.**  In  the  MASSPIRG 
scenarios,  therefore,  it  is  also  assumed 
that  BECO  will  recover  64  percent  of 
its  current  investment  in  fuel,  materials 
and  supplies  through  sales  to  other 
utilities. 

If  Pilgrim  were  retired,  it  would  ac- 
tually be  up  to  the  Department  of 
Public  Utihties  (DPU)  to  determine 
who  should  pay  for  Pilgrim  sunk  costs. 
Under  a  policy  adopted  in  a  Western 
Massachusetts  Electric  Company  case 
in  1984,  the  DPU  ruled  that  sunk  cost 
recovery  would  no  longer  be  allowed 
for  investments  that  were  not  "used  and 
useful"  to  utility  customers,  such  as 
plants  that  were  canceled  while  still 
under  construction.     In  a  1985 
decision  on  excess  capacity,  the  Depart- 
ment modified  its  policy  to  allow 
utilities  to  recover  uneconomic  invest- 
ments over  time,  but  without  charging 


11 


298 


20 

ratepayers  for  financing  charges.    This 
policy,  which  is  followed  by  most  state 
utility  commissions,  results  in  a  sharing  of 
sunk  costs  between  utility  ratepayers  and 
investors.  Stockholders  are  also  able  to 
share  their  losses  with  the  federal  govern- 
ment, which  allows  generous  tax  deduc- 

21 

tions  for  investment  losses. 


D.  Alternative  scenarios  show 
savings  from  retiring  Pilgrim. 


Three  scenarios  were  constructed  to 
cover  the  widest  reasonable  range  of  as- 
sumptions for  the  costs  of  operating  or 
retiring  Pilgrim.  The  Pilgrim  Optimistic 
Case  combines  all  the  assumptions 


Table  1.  ALTERNATIVE  ASSUMPTIONS  USED  IN  MASSPIRG  PILGRIM     J 

PROJECTIONS 

'Capacity  Capital  O&M  Replacement 

Factor  Additions  Expenses  Power 


Pil^m 
Tfistorical 
Trend  Case 

Pil^im 
Historical 

50% 

Pilgriin 
Histoi  ical 
to  years 

Pilgrim 
Historical 

Averge  of 
Aw'ard  Group 
QFs 

Natiohaf 

Ttend 

Case 

National 
Trend 
Pilgrim  to  4/86 

56% 

National 
Trend 
5  years 

liaiiuqal 
Treiid 

Average  of 

Next  740  MW 
QFs 

Pilgrim 

Optimistic 

C«se 

National  avg. 

aUBWRs 

63.2% 

Pilgrim 

Low  Historical 

5  years 

2%  Real 
Escalation 

Average  of 

all  1327  KfW 

Unsigned  QFs                         ; 

Boston 
Edison 

70% 

05%  Real 
Escalation 

0.5%  Real 
Escalation 

Awrage  of 

all  132?  MW 

Unsigied  QFs                           j 

Table  2.  ADDITIONAL  CONSERVATISMS  IN  ALL  SCENARIOS 


Jtudear^vastc 

disposal:  No  increases  from  current  BECO  assumptions 

^utdown:      :;;  No  savings  from  early  decommissioning 

(Opacity  factor  No  declining  effect  from  salt-water  cooling 

Capital  Additions:  No  increases  after  5- 10  years 

BECO-assnmed  decreases  in  last  five  years  of  operation 
No  repeat  of  1984  and  1987  major  repairs 

O&Mand 

Capital  AddUions:  Linear  rather  than  exponential  trend  increases 

Miscellaneous:    "W-year  lifetime 

No  increases  in  nucleai  insurancf 

No  serious  acc'dents 

No  societal  costs 

No  nuclear  subsidies  included  in  Plgrim  costs 


12 


299 


Figure  11 

PILGRIM  OPERATION  VS  RETIREMENT 
Present  Value  (Billion  1987  $) 


^ 


h^ 


m 


^^^,^    Repl.Power 


most  favorable  to  Pilgrim  —  the  most  op- 
timistic projections  of  Pilgrim  costs,  and 
the  highest  price  for  replacement  power, 
equal  to  the  average  bids  of  all  non- 
Award  Group  QFs.  The  National  Trend 
Case  assumes  that  Pilgrim  costs  improve 
to  the  level  predicted  by  the  national 
trend  for  a  plant  with  Pilgrim's  charac- 
teristics. A  middle  estimate  of  replace- 
ment power  is  used,  equal  to  the  price  of 
the  least  expensive  740  Mw  of  QF  bids 
after  the  Award  Group.  The  Pilgrim  His- 
torical Case  assumes  that  all  Pilgrim  cost 
components  follow  the  same  trends  they 
have  in  the  past,  and  that  replacement 
power  could  be  obtained  for  the  price  of 
the  Award  Group  bids  from  QFs.  Table  1 


Shutdown 


Sunk 


summarizes  the  assumptions  employed 
in  each  scenario.  Table  2  hsu.  the  addi- 
tional assumptions  favorable  to  Pilgrim 
that  were  made  in  all  MASSPIRG 
scenarios. 

The  alternative  scenarios  indicate 
that  the  present  value  of  savings  to 
ratepayers  from  retiring  the  plant 
would  range  from  $46  million  to  $1.6 
billion  over  25  years,  even  if  ratepayers 
were  to  pay  for  all  sunk  costs  (Table  3; 
Figure  11).  The  $1.6  billion  savings  is 
approximately  equal  to  $540  for  the 
average  Edison  residential  customer.  If 
investors  were  to  pay  sunk  costs,  the 
savings  from  retiring  Pilgrim  would  in- 
crease to  a  range  of  $769  million  to 


SAVINGS  TO  RATEPAVEJK  FROM  RETIRING  PILGRIM 

Ratepayers  Pay 
Sonk  Costs 

Investors  Piay 
Sunk  C^ts 

Pilgrim  Historical 
"trend  Case 

S1.56  bUIion 

$2.28  billion 

Nsttlortal 
TmtdCase 

$813  million 

$1.54  billion 

Pi^m  Qptinistic 
Case 

S49  million 

$773  million 

BECO                            • 

AjHHUBptiotU 

-$611  million 

$168niillJon 

13 

300 


$2.3  billion.  Detailed  annual  costs  for  all 
scenarios  are  presented  in  Appendix  A. 

Figure  12  illustrates  how  the  present 
value  of  the  cumulative  savings  from  retir- 
ing Pilgrim  changes  over  time  in  each 
scenario,  assuming  that  ratepayers  pay  for 
the  full  sunk  costs,  including  a  profit  on 
Pilgrim  investment  to  date.  The  cumula- 
tive savings  at  any  point  in  time  is  equal 
to  the  difference  between  total  Pilgrim 
costs  and  the  total  costs  of  replacement 
power,  shutdown  and  sunk  costs  to  that 
time. 

Graphs  of  cumulative  savings  are  espe- 
cially useful  for  looking  at  the  effect  of 
changing  only  one  assumption  at  a  time 
on  the  benefits  of  retiring  Pilgrim.  Figure 

Figure  12 

CUMULATIVE  SAVINGS  FROM 
Present  Value  (Billion 


13  illustrates  the  effect  of  changing 
only  the  assumption  about  how 
regulators  might  deal  with  Pilgrim  sunk 
costs  if  the  plant  were  retired.  The  mid- 
dle line  represents  the  usual  regulatory 
practice  for  plants  canceled  under  con- 
struction, where  ratepayers  would 
repay  all  sunk  costs  over  time  but  with 
the  utility  earning  no  profit  on  its  sunk 
investment.  In  this  case,  it  is  assumed 
that  Pilgrim  sunk  costs  would  be 
charged  to  ratepayers  over  the  same  25 
year  period  as  they  would  have  been  if 
the  plant  had  operated.  Under  tradi- 
tional regulatory  practice,  ratepayers 
would  save  money,  at  least  through  the 
year  2008,  by  retiring  Pilgrim,  even  if 
all  BECO  assumptions  about  the 
plant's  future  costs  hold. 

RETIRING  PILG. 
1987$) 


rfS^rend 


Pilg.Trend 


Figure  13 

CUMULATIVE  SAVINGS  FROM  RETIRING  PILG 
BECO  Assumptions  Except  Sunk  Costs 


InvestorB  pay 


Customers  pay 


14 


301 


4.  Conclusions  and  Recommendations 


Retiring  Pilgrim  would  clearly  save 
utility  customers  money,  under  a  wide 
range  of  reasonable  assumptions,  even  if 
ratepayers  have  to  pay  a  full  return  on  the 
sunk  costs  of  the  plant.  The  Pilgrim 
nuclear  plant  should  therefore  be  im- 
mediately and  permanently  retired. 

While  no  state  official  or  agency  has 
the  direct  authority  to  order  the  shutdown 
or  retirement  of  a  nuclear  plant,  the  Mas- 
sachusetts Department  of  Public  Utilities 
(DPU)  is  responsible  for  determining 
what,  if  any,  utility  investments  and  expen- 
ses can  be  charged  to  ratepayers,  under  a 
broad  statutory  mandate  to  ensure  just 
and  reasonable  electric  rates.  If  it  were  to 
determine  that  ongoing  investment  in 
Pilgrim  were  imeconomical,  the  DPU 
could  prohibit  its  owners  from  financing 
or  charging  ratepayers  for  future  invest- 
ment in  the  plant. 

MASSPIRG  therefore  recommends 
that  the  DPU  disallow  recovery  of  any  ad- 
ditional Pilgrim  investment,  including  the 
$150  million  in  capital  additions  Boston 
Edison  has  budgeted  to  spend  in  1987.  A 
second  round  of  bidding  from  potential 
power  suppliers  should  be  initiated,  with 


reasonable  assumptions  about  Pilgrim 
costs  used  to  set  a  target  for  acceptable 
bids.  Energy  efficiency  contractors, 
who  could  seU  energy  savings  to  the 
utility,  should  also  be  encouraged  to 
compete  with  QFs  in  bidding  to  replace 
Pilgrim. 

A  similar  process  for  dealing  with 
new  power  plant  construction  has 
recently  been  proposed  to  the  DPU  by 
the  state  Executive  Office  of  Energy 
Resources.     Decisions  to  continue  in- 
vesting in  plants  that  have  already  been 
in  operation  are  no  different  from 
decisions  to  start  new  construction,  or 
to  complete  partially  built  plants.  In 
each  case,  the  ongoing  investment  must 
be  weighed  against  potential  alterna- 
tives. New  utility  investment  in  power 
plants  should  be  allowed  only  if  it 
would  be  "used  and  useful"  ~  necessary 
to  provide  rehable  electric  service  and 
the  most  economical  alternative.  To 
the  extent  that  the  Pilgrim  plant  cannot 
meet  that  test  —  and  this  report  finds 
that  it  carmot  ~  the  plant  should  be  per- 
manently retired. 


15 


302 


APPENDIX  A 

ANNUAL  COSTS  OF  PILGRIM  VS.  ALTERNATIVES 
BECO  ASSUMPTIONS 


Year 

:ap- 

IqUI 

Snn. 

OccvK-  Net 

[)e- 

Na-  1 

■uel 

Avg. 

Re- 

In- 

De- 

n- 

.0- 

Oe-  Fuel 

K<I1 

-  PILSRW  TOTAL 

— ;• 

.-  IFs  -; 

tal 

Plant 

De- 

ilated  Plant 

(er- 

ter- 

Rate 

turn  co«e 

3re-  sur-  cal 

■.m 

AnnualCost 

n- 

^ost 

Cost 

ftd- 

Year 

pre- 

Depre- 

fear- red 

lals 

Base 

on 

rax 

cia- 

)nce 

rax 

•is- 

Costs 

in 

cre- 

m 

in 

Vinuo 

di- 

End 

cia- 

cia- 

:nd 

Tax 

Rate 

tion 

sion- 

[:ents 

■en- 

Cents 

Cents 

lOi'. 

ions 

tion 

tion 

Base 

inj 

aer 

tal 

per 

per 

( 

in  11 

Uions 

o-f  dollars  ) 

kHh 

(iBil.)knh 

KlUh 

m.l. 

ira? 

150 

846 

24 

176 

670 

-104 

20 

51 

542 

56 

27 

24 

5 

11 

4 

1 

97 

227 

5.5 

1 

0.0 

3.3 

.3« 

1988 

40 

886 

28 

204 

682 

-113 

21 

51 

421 

44 

30 

2B 

5 

11 

5 

27 

99 

268 

6.5 

92 

2.2 

3.5 

14; 

IW 

40 

926 

29 

233 

693 

-122 

22 

50 

623 

44 

30 

29 

5 

11 

5 

24 

107 

276 

6.7 

126 

3.1 

3.4 

Ni 

IW 

70 

996 

32 

265 

731 

-130 

23 

50 

440 

66 

31 

32 

5 

12 

5 

24 

120 

294 

7.2 

152 

3.7 

3.7 

152 

1991 

40 

1036 

34 

299 

737 

-138 

24 

50 

454 

6B 

32 

34 

6 

12 

5 

24 

125 

305 

7.4 

169 

4.1 

4.2 

174 

1992 

42 

1078 

36 

335 

743 

-143 

24 

50 

655 

48 

32 

36 

4 

12 

6 

24 

131 

314 

7.4 

135 

4.5 

5.7 

232 

1997 

44 

1122 

38 

373 

749 

-147 

27 

54 

661 

48 

32 

36 

4 

12 

4 

24 

138 

326 

7.9 

202 

4.9 

4.1 

251 

1994 

46 

1168 

41 

414 

754 

-146 

28 

56 

670 

49 

33 

41 

6 

12 

7 

27 

145 

339 

6.3 

24',' 

5.8 

4.6 

272 

1995 

49 

1217 

43 

457 

760 

-143 

30 

60 

683 

71 

33 

43 

7 

12 

7 

29 

152 

353 

8.4 

258 

6.3 

7.2 

29» 

1996 

51 

1268 

46 

503 

765 

-139 

31 

66 

697 

72 

34 

44 

7 

13 

7 

31 

140 

370 

9.0 

278 

6.8 

7.8 

32'J 

1997 

54 

1322 

49 

553 

769 

-136 

33 

67 

706 

73 

35 

49 

7 

12 

8 

32 

148 

384 

9.3 

294 

7.2 

8.5 

349 

1998 

5b 

1J78 

53 

606 

772 

-133 

34 

75 

721 

74 

35 

53 

6 

12 

8 

34 

174 

403 

9.8 

316 

7.7 

9.2 

378 

1999 

59 

14J7 

57 

663 

774 

-129 

36 

75 

726 

75 

36 

57 

8 

12 

9 

34 

185 

41B 

10.2 

334 

8.1 

10.2 

42': 

2000 

62 

1499 

62 

725 

774 

-126 

38 

84 

739 

76 

34 

42 

9 

13 

9 

40 

194 

439 

10.7 

358 

8.7 

11.1 

45' 

2001 

65 

1564 

67 

792 

772 

-121 

40 

84 

742 

77 

34 

47 

9 

13 

10 

40 

204 

455 

11.1 

377 

9.2 

12.0 

491 

2002 

68 

1633 

73 

366 

767 

-115 

42 

92 

752 

78 

37 

73 

9 

12 

11 

44 

214 

478 

11.6 

402 

9.8 

13.2 

54 

200J 

72 

1705 

80 

946 

759 

-105 

44 

94 

755 

78 

37 

80 

10 

12 

11 

45 

225 

498 

12.1 

425 

10.3 

13.9 

573 

2'M 

75 

1780 

88 

1035 

746 

-93 

46 

99 

760 

79 

37 

88 

10 

12 

12 

47 

234 

522 

12.7 

451 

11.0 

15.1 

421 

2005 

79 

1859 

98 

1133 

727 

-78 

48 

105 

742 

79 

37 

98 

11 

11 

13 

50 

248 

547 

13.3 

476 

11.6 

16.5 

bV 

2004 

83 

1942 

110 

1242 

700 

-60 

51 

111 

741 

79 

37 

110 

11 

11 

14 

53 

240 

575 

14.0 

508 

12.4 

17.8 

729 

2007 

87 

2030 

124 

1366 

663 

-37 

53 

118 

754 

78 

37 

124 

12 

11 

15 

54 

273 

605 

14.7 

540 

13.2 

16.6 

765 

2008 

70 

2100 

140 

1506 

594 

-9 

43 

125 

718 

74 

35 

140 

13 

9 

14 

59 

287 

633 

15.4 

570 

13.9 

19.9 

819 

20O9 

56 

2156 

155 

1661 

494 

26 

34 

94 

619 

64 

30 

155 

13 

8 

17 

43 

301 

652 

15,9 

591 

14.4 

21.2 

970 

2010 

45 

2200 

172 

1834 

367 

66 

27 

62 

500 

52 

24 

172 

14 

6 

19 

67 

314 

449 

16.3 

610 

14.8 

22.5 

922 

2011 

36 

2236 

192 

2026 

210 

MS 

22 

31 

341 

37 

18 

192 

15 

3 

21 

71 

332 

488 

16.7 

629 

15.3 

23.6 

979 

2012 

29 

2265 

239 

2265 

0 

0 

17 

0 

3 

0 

0 

239 

15 

0 

11 

75 

348 

488 

16.8 

645 

15.7 

25,3 

1038 

2013 

139 

20M 

70 

2015 

70 

201& 

70 

2017 

70 

2018 

70 

Total 

Present 

1 

• 

Value 

3287 

2302 

2913 

16 


303 


ANNUAL  COSrS  OF  PILGRIM  VS.  ALTERNATIVES 


OPTIMISTIC  CASE 


Ve.i- 

>- 

Total 

Ann. 

ftccuii-  Net 

De- 

Ma- 

■uel 

Avj. 

Re- 

In- 

De- 

n- 

.0- 

De- 

■uel 

OW 

-  PILBRIN  TOTAL 

— > 

:  <-  UFs  -;- 

tal 

Plant  De- 

jiated  Plant 

fer- 

ter- 

Rate 

turn  co«e 

ore-  sur-  cal 

:m 

flnnualCcret 

In- 

Cost 

Cost 

M- 

Veap 

pre- 

Bepre- 

If  ear- 

red 

ials 

Base 

on 

rax 

ela- 

uice 

Tax 

ms- 

kists 

in 

cre- 

in 

1  in   i^nus 

ji- 

End 

cia- 

::a- 

End 

Tax 

Rate 

tion 

sion- 

Cents 

■en- 

Cents 

,  Cents 

as'. 

lons 

tion 

tion 

Base 

ing 

per 

tal 

per 

per 

( 

in  11 

Uions 

0* 

Jollars  ) 

kwh 

(■il.) 

kNh 

;  kHh 

B\\. 

ive7 

150 

846 

24 

176 

670 

-104 

20 

51 

562 

58 

27 

24 

5 

U 

4 

1 

97 

226 

6.1 

B 

0.2 

1   3.3 

3( 

1988 

45 

891 

28 

204 

687 

-113 

21 

51 

624 

64 

30 

28 

5 

11 

5 

24 

99 

266 

7.2 

98 

2.7 

1   3.5 

13i 

1989 

50 

941 

30 

234 

707 

-122 

22 

50 

633 

65 

31 

3(1 

5 

11 

5 

21 

107 

275 

7.4 

134 

3.6 

;   3.6 

13, 

1990 

70 

1011 

32 

266 

745 

-130 

23 

50 

653 

67 

32 

32 

5 

12 

5 

21 

120 

295 

7.° 

160 

4.3 

•   J.  7 

i:t 

1991 

60 

1071 

35 

301 

770 

-139 

24 

50 

675 

70 

33 

35 

6 

12 

5 

21 

125 

308 

8.3 

179 

4.8 

:  4.2 

157 

1992 

66 

1137 

38 

339 

798 

-145 

26 

50 

695 

n 

34 

38 

6 

13 

6 

21 

131 

321 

8.6 

199 

5.4 

;  5.7 

2K 

1995 

69 

1206 

42 

381 

825 

-150 

27 

54 

722 

75 

35 

42 

6 

13 

6 

23 

138 

338 

9.1 

220 

5.9 

;  6.1 

2. 

1994 

73 

1279 

45 

426 

853 

-150 

28 

56 

751 

78 

37 

45 

6 

14 

7 

24 

145 

355 

9.6 

263 

7..1 

.   6.6 

2f> 

1995 

76 

1356 

49 

476 

880 

-148 

30 

60 

783 

81 

38 

49 

7 

14 

7 

26 

152 

374 

10.1 

285 

7.7 

,   7.2 

266 

1996 

80 

1436 

54 

530 

906 

-147 

31 

66 

816 

84 

40 

54 

7 

15 

7 

28 

161 

396 

10.7 

7,'ii 

B.« 

:   '.8 

289 

1997 

84 

1520 

59 

589 

931 

-145 

33 

67 

843 

87 

41 

59 

7 

15 

8 

29 

172 

418 

li.3 

334 

9.' 

;  8.5 

:ii 

1998 

89 

1609 

65 

654 

954 

-144 

34 

75 

876 

91 

43 

65 

8 

15 

8 

32 

183 

445 

12.0 

564 

9.8 

i   9.2 

•Al 

1999 

93 

1702 

71 

726 

976 

-142 

36 

75 

899 

93 

44 

71 

8 

15 

9 

32 

195 

468 

12.6 

390 

10.5 

1  10.2 

^1  1 

:»oo 

98 

1799 

79 

805 

995 

-139 

38 

84 

929 

94 

45 

79 

9 

16 

9 

36 

206 

498 

13.4 

422 

11.4 

:  u.i 

412 

2001 

102 

1902 

87 

892 

1010 

-136 

40 

84 

947 

98 

46 

87 

9 

16 

10 

36 

222 

524 

14.1 

451 

12.2 

:  12.0 

4*3 

2002 

108 

2009 

97 

988 

1021 

-130 

42 

92 

971 

100 

47 

97 

9 

16 

11 

40 

256 

556 

15.0 

485 

13.1 

;  13.2 

498 

2003 

113 

2122 

108 

1096 

1026 

-120 

44 

94 

987 

102 

48 

108 

10 

16 

11 

40 

251 

586 

15.8 

517 

14.0' 

;  13.9 

517 

2004 

119 

2241 

121 

1217 

1024 

-108 

46 

99 

1002 

104 

49 

121 

10 

16 

12 

45 

267 

622 

16.8 

555 

15.0 

;  15.1 

So. 

2005 

125 

2366 

136 

1353 

1013 

-91 

48 

105 

1013 

105 

50 

136 

11 

15 

13 

45 

284 

659 

17.8 

593 

16.0 

■  16.5 

611 

2004 

131 

2496 

154 

1507 

990 

-68 

51 

111 

1018 

105 

50 

154 

11 

15 

14 

48 

503 

700 

18.9 

657 

17.2 

1  17.8 

6" 

»07 

137 

2634 

176 

1683 

951 

-39 

53 

118 

1014 

105 

50 

176 

12 

14 

15 

51 

522 

745 

20.1 

685 

18.4 

1  18.0 

6'71 

2008 

110 

2744 

201 

1884 

859 

-2 

43 

125 

970 

100 

47 

201 

13 

13 

16 

54 

543 

786 

21.2 

726 

19.6 

1  19.9 

'41 

2009 

88 

2831 

226 

2110 

721 

44 

34 

94 

849 

88 

42 

226 

13 

11 

17 

57 

365 

818 

22.1 

760 

20.5 

;  21.2 

786 

2010 

70 

2902 

252 

2362 

540 

101 

27 

62 

695 

72 

34 

252 

14 

8 

19 

60 

389 

848 

22.9 

790 

21.3 

:     22.5 

833 

2011 

56 

2956 

284 

2646 

312 

171 

22 

31 

506 

53 

25 

284 

15 

5 

21 

64 

414 

879 

23.7 

822 

22.2 

:  25.  s 

89: 

2012 

45 

3003 

357 

3003 

0 

263 

17 

0 

257 

27 

13 

557 

15 

0 

U 

68 

440 

930 

25.1 

886 

23.9 

;  25.3 

93 

2013 

176 

2014 

88 

2015 

88 

2016 

88 

2017 

B8 

20iB 

88 

lo^al 

Present 
ValLe 

3408 

2679 

1 

262^ 

17 


304 


ANNUAL  COSTS  OF  PILGRIM  VS.  ALTERNATIVES 
NATIONAL  TREND  CASE 


Zif-  Total  tnn.   Accii*-  Net   De-   Na-  Fuel  flvg.  Re-  In-  De-  In-  Lo-  De-  Fuel  0M1 


lUl  Plant  De-  ulated  Plant  fer- 

Ad-  Year  pre-  Depre-  Year-  red 

di-  End  cia-  cia-   End   Tax 

tions  tion  t\ot\ 


ter-    Rate  tum  co«e  pre-  sur-  cal  coa 

lals    Base  on   Tax  cia-  ance  Tax  iis- 

Rate     tion  sion- 

Base  inj 


iva? 

1988 
1987 
1990 
1991 
1992 
1993 
1994 
1995 
1996 
1997 
1998 
1999 
2000 
2001 
2002 
2003 
2004 
2005 
2006 
2007 
2006 
2009 
2010 
2011 
2012 
2013 
2014 
2015 
2016 
2017 
2018 


150 
62 
68 


846 
908 
976 


75  1051 

82  1133 

90  1223 

94  1318 

99  1417 

104  1521 

109  1630 

115  1745 

121  1865 

127  1992 


24 
28 
31 
34 
37 
42 
46 
51 
57 
63 
70 
78 
87 

133  2125  97 
139  2264  108 
146  2411  121 
154  2564  136 
161  2726  154 
170  2896  174 
178  3074  199 
187  3261  230 
150  3410  263 
120  3530  297 
96  3625  333 
77  3702  376 
61  3763  475 


( 

176 
204 
235 
269 
306 
348 
394 
445 


in  (illicms  of   dollars  ) 


670 

704 

741 

782 

827 

875 

923 

971 

502  1019 

565  1065 

635  1109 

713  1152 

800  1192 

897  1228 

1005  1259 

1126  1284 

1262  1302 

1416  1310 

1590  1305 

1790  1284 

2019  1241 

2282  1128 

2579   950 


2912 
3288 
3763 


713 

414 

0 


-104  20 

-113  21 

-123  22 

-132  23 

-141  24 

-148  26 

-155  27 

-156  28 

-157  30 

-157  31 

-157  33 

-157  34 

-157  36 

-156  38 

-154  40 

-149  42 

-139  44 

-125  46 

-106  48 

-80  51 

-44  53 


2 
61 


135  27 
227  22 
346  17 


51  562 
51  632 
50  657 
50  686 
50  719 
50  758 
54  803 
56  850 
60  900 

66  951 

67  995 
75  1044 
75  1083  112 
84  1127  117 
84  1159  120 
92  1196  124 
94  1224  126 
99  1249  129 

105  1267  131 
111  1277  132 
118  1275  132 
125  1223  126 

94  1080  112 

62  890 

31  655 
0  333 


58 
65 
68 
71 
74 
78 
83 
88 
93 
98 
103 
108 


92 
68 
54 


27 
31 
32 
34 
35 
37 
39 
42 
44 
46 
49 
51 
53 
55 


24 
28 
31 
34 
37 
42 
46 
51 
57 
63 
70 
78 
87 
97 


57  108 

58  121 

60  136 

61  154 

62  174 
62  199 
62  230 
60  263 
53  297 
44  333 
32  376 
16  475 


11 
11 
12 
12 
13 
14 
H 
15 
16 
17 
17 
8   18 

8  IB 

9  19 
9  20 
9   19 

10   20 

10  20 

11  19 


11 
12 
13 
13 
14 
15 
15 


9 
9 
10 
11 
11 
12 
13 
14 
15 
16 
17 
19 
21 
11 


PILGRIM  TOTAL  -> 

AnnualCost  In-   Cost 

Costs  in   ere-  in 

Cents  aen-  Cents 

per   tal   per 

I^Nh   (•il.lkNti 


1 

r 


97 
99 


19  107 

19  120 

19  125 

19  131 


138 
145 


23  152 

25  161 

26  174 
29  188 
29  204 
32  219 
32  236 

35  254 

36  272 
38  292 
40  313 
42  336 
45  359 
47  385 
50  411 
53  440 
56  470 
60  501 

201 
100 
100 
100 
100 
lOO 


226 
265 
278 
299 
315 
332 
353 
375 
398 
425 
454 
488 
519 
557 
591 
631 
671 
716 
763 
816 
873 
926 
967 
1004 
1043 
1113 


6.9 
8.1 
8.5 
9.1 
9.6 
10.1 
10.8 
11.4 
12.1 
12.9 
13.8 
14.8 
15.8 
16.9 
18.0 
19.2 
20.4 
21.8 
23.2 
24.8 
26.5 
28.2 
29.4 
».6 
31.7 
33.9 


97 
137 
165 
187 
210 
236 
283 
309 
339 
370 
407 
441 
481 
518 
560 
602 
649 
698 
753 
811 
866 
909 
947 
986 
1069 


0.2 

3.0 

4.2 

5.0 

5.7 

6.4 

7.2 

8.6 

9.4 

10.3 

11.3 

12.4 

13.4 

14.6 

15.8 

17.0 

18.3 

19.8 

21.2 

22.9 

24.7 

26.3 

27.6 

28.8 

30.0 

32.5 


-  QFs  -:■ 
Cost 

in    Annua' 
Cents  Cost 

KMh   Inil.- 


3.4 

3.6 

3.6 

^.2 

5.7 

4.1 

6.5 

7.0 

7.5 

8.2 

8.7 

9.6 

10.3 

11.0 

12.0 

12.7 

13.6 

14.7 

15.8 

16.5 

17.6 

18.6 

19.7 

20.9 

22.2 


27 
113 
117 
119 
136 
186 
200 
215 
230 
248 
268 
288 
314 
340 
362 
394 
417 
448 
484 
519 
541 
578 
612 
648 
688 
731 


I'otal 

'resent 

aiue 


3928 


2998 


2185 


18 


305 


AWIUAL  COSTS  OF  'ILGRIM  VS.  ALTERNATIVES 
PILGRIM  TREND  CASE 


ZAf- 

Total  Ann. 

taujr  Net 

De-  Ha-  Fuel  flvg. 

Re- 

n- 

te- 

n-  Lo- 

3e-  Fuel  Otfl  < 

-  PILGRIM  TOTAL 

— > 

<~  QF-s 

itii 

Plant  De- 

jlated  Plant 

Fer-  ter- 

Rate  turn  coae 

jre-  sur-  cal  co« 

AnnualCost 

n- 

:ost  I 

Cost 

M- 

Vear 

pre- 

Depre- 

Year-  red   lals 

Base 

un 

Fax 

:ia-  ance 

Fax 

nis- 

Costs 

in 

:  re- 

in 

in   t^ifi'  ■-■-. 

ii- 

End 

:ia- 

:ia- 

End 

Fax 

Rate 

tion 

sion- 

:ent5 

ci- 

:ents . 

Cents  C 

ys- 

tions 

tion 

tion 

Base 

ins 

per 

tal 

per 

per 

( 

in  «i 

lions  of  dollars  ) 

kNh 

■il.lkHh 

i-.iit      ■■ 

ITiJ  .  ■' 

-07 

1^0 

844 

24 

174 

470 

-104  20 

51  542 

58 

27 

24 

5 

11 

4 

1 

97 

226 

7.7 

8 

0.3 

3.3 

'ce 

66 

912 

28 

205 

708 

-113  21 

51  434 

45 

31 

22 

5 

11 

5 

19 

99 

263 

9.0 

95 

3.3 

3.3 

1^ 

>B9 

73 

985 

31 

234 

750 

-123  22 

50  463 

69 

32 

31 

5 

12 

S 

17 

107 

277 

9.4 

136 

4.6 

3.5 

10- 

•?o 

80 

104i 

34 

270 

794 

-132  23 

50  497 

72 

34 

34 

5 

13 

5 

17 

120 

300 

10.2 

165 

5.6 

".4 

10- 

■V! 

88 

1154 

38 

308 

844 

-142  24 

50  734 

76 

36 

38 

6 

13 

5 

17 

125 

314 

10.8 

188 

6.4 

4.0 

lia 

■h'i 

97 

1251 

43 

351 

900 

-149  26 

50  778 

80 

38 

43 

6 

14 

6 

17 

131 

335 

11.4 

213 

7.2 

5.7 

16 

I'S 

m 

1354 

48 

398 

958 

-154  27 

54  830 

84 

41 

48 

b 

15 

6 

18 

133 

357 

12.2 

240 

3.2 

6.0 

ir 

;.« 

116 

1472 

53 

452 

1020 

-159  28 

54  888 

92 

43 

53 

6 

16 

7 

19 

146 

382 

13.0 

29f: 

9.9 

6.4 

'9' 

;?5 

126 

1598 

40 

512 

1064 

-140  30 

40  953 

9V 

47 

60 

7 

17 

7 

20 

159 

415 

14.2 

326 

11.1 

6.8 

199 

■'  c 

133 

1734 

48 

580 

1154 

-141  31 

44  1024 

106 

50 

68 

7 

18 

7 

22 

173 

452 

15.4 

364 

12.5 

7  "^ 

2;i 

"17 

150 

1884 

77 

457 

1229 

-142  33 

47  1092 

113 

53 

77 

7 

19 

8 

23 

139 

489 

16.7 

405 

13.3 

7.4 

T?" 

■/2 

157 

2043 

87 

744 

1299 

-144  34 

75  1147 

121 

57 

87 

8 

20 

8 

24 

205 

532 

18.1 

451 

15.4 

8.0 

2.i 

>'.'! 

lis 

2209 

99 

843 

1344 

-145  34 

75  1230 

127 

60 

99 

8 

21 

9 

26 

223 

572 

19.5 

494 

16.8 

3.5 

2"' 

■'.■(' 

174 

2382 

112 

954 

1428 

-165  38 

84  1298 

134 

63 

112 

9 

22 

9 

29 

241 

419 

21.1 

543 

18.5 

9.1 

:>■ 

';■:'( 

182 

2545 

127 

1081 

1484 

-144  40 

84  1352 

140 

66 

127 

9 

23 

10 

29 

260 

463 

22.4 

590 

20.1 

9.5 

7H:. 

'02 

191 

2754 

144 

1225 

1532 

-140  42 

92  1410 

146 

69 

144 

9 

23 

11 

31 

280 

713 

24.3 

642 

21.9 

10.1 

y<' 

IT 

201 

2957 

163 

1388 

1569 

-150  44 

94  1457 

151 

71 

143 

10 

23 

11 

32 

302 

763 

26.0 

695 

23.7 

•  10.7 

.!■. 

iM 

211 

3148 

184 

1574 

1594 

-135  46 

99  1499 

155 

73 

134 

10 

24 

12 

34 

325 

819 

27.9 

753 

25.6 

11.3 

3;. 

0''!: 

222 

3390 

213 

1787 

1403 

-113  48 

105  1532 

158 

75 

213 

11 

23 

13 

36 

349 

878 

29.9 

313 

27.7 

'  12.0 

3^? 

'  J 

233 

3423 

244 

2033 

1590 

-83  51 

111  1553 

161 

76 

244 

11 

23 

14 

38 

375 

944 

32.2 

381 

30.0 

12.7 

'7 

OC/ 

244 

3847 

285 

2318 

1549 

-41  53 

118  1557 

161 

76 

285 

12 

22 

15 

40 

403 

1014 

34.6 

952 

32.5 

;  13.1 

3€; 

3 

195 

4042 

329 

2447 

1415 

15  43 

125  1500 

155 

73 

329 

13 

19 

16 

42 

432 

1080 

36.8 

1020 

34.8 

!3.9 

v- 

'■'? 

156 

4219 

373 

3021 

1198 

88  34 

94  1335 

138 

45 

373 

13 

17 

17 

45 

463 

1133 

38.4 

1074 

36.6 

1  14.6 

427 

-\-J 

125 

4344 

420 

3441 

903 

178  27 

42  1108 

US 

54 

420 

14 

13 

19 

48 

496 

1179 

40.2 

1121 

38.2 

15.5 

'IS- 

■■'■  1 

100 

4444 

474 

3917 

527 

292  22 

31  822 

85 

40 

474 

15 

7 

21 

50 

531 

1226 

41.8 

1169 

39.8 

!  14.5 

4, 

O.'-i 

80 

4524 

407 

4524 

0 

444  17 

0  421 

44 

21 

407 

15 

0 

11 

54 

568 

1318 

44.9 

1274 

43.4 

17.5 

51' 

"■-5 

227 

■lA 

114 

■;5 

114 

'^'.';; 

114 

/7 

114 

'.3 

J14 

w;M:*t 


4236 


3306 


175 


306 


Notes  to  Appendix  A 
Assumptions  and  Metiiods 


Capital  Additions: 

BECQ:  Escalation  of  approxiniately  .5  percent  per  year,  after  adjusting  for  inflation,  from  about  $30  mil- 
lion per  year  (1986  constant  dollars).  Declines  by  23  percent  a  year  over  last  five  years  of  plant's  life. 

Optimistjr.-  Ljnear  growth  at  $2.5  million  per  year  for  five  years  to  approximately  $50  nullion  per  year 
(1986  dollars),  followed  by  same  escalation  and  decline  as  BECO.  Derived  from  Unear  regression  of 
Pilgrim  historical  experience  between  1973  and  1976,  treating  the  four  years  with  expenditures  significant- 
ly above  the  trend  line  as  one-time  expenditures  which  will  not  recur. 

National  Trend:  Linear  growth  at  $3.2  million  per  year  for  five  years  to  $69  million  per  year  (1986  $),  fol- 
lowed by  same  pattern  as  BECO.  Derived  from  ESRG  multi-variate  regression  equation  applied  to 
Pilgrim. 

Pilgrim  Trend: 

Linear  growth  at  $3-5  million  per  year  for  10  years  to  $92  million  per  year  year  (1986$),  followed  by  same 
pattern  as  BECO.  Derived  from  linear  regression,  excluding  two  largest  outliers. 

Plant-in-Service  Year  End: 

Calculated  as  in  BECO  Exhibit  1. 

=  Capital  Additions  +  Prior  Total  Plant  Year  End 

Annual  Depreciation: 

=  (Half  of  Year's  Capital  Additions  -I-  Prior  Year  Net  Plant)  /  Remaining  Life 

Deferred  Taxes: 

Calculated  as  in  BECO  Exhibit  2. 

Prior  Year  Accumulated  Deferred  Taxes  +  (Tax  Rate  x  (Year's  Tax  Depreciation  -  Year's  Book 
Depreciation)) 

Year's  Tax  Depreciation  calculated  as  in  BECO  Exhibit  2  (150%  Double  Declining  Balance). 

Materials  &  Supplies: 

From  BECO  Exhibit  1. 

Nuclear  Fuel  in  Rate  Base: 

From  BECO  Exhibit  1. 

Average  Rate  Base: 

Calculated  as  in  BECO  Exhibit  1. 

=  Net  plant  Year  End  +  Deferred  Taxes  ^-  Materials  &  Supplies  -t-  Nuclear  Fuel  in  Rate  Base  -  Half  of 
Year's  Capital  Additions 


Return  on  Rate  Base: 

Calculated  as  in  BECO  Exhibit  1. 

=  Average  Rate  Base  x  10.338% 


20 


307 


Income  Taxes: 

CaloJated  as  in  BECO  Exhibit  1. 

=  Average  Rate  Base  x  4J?9% 

Insurance 

From  BECO  Exhibit  1. 

Local  Taxes 

Calculated  as  in  BECO  Exhibit  1. 

=  Average  Rate  Base  x  1S% 

Decommissioning  contribution: 

From  BECO  Exhibit  1. 

Sinking  fund  to  accumulate  $126  million  (1986$)  by  2012. 

Fuel: 

Calculated  from  BECO  Exhibit  1. 

BECO's  annual  fuel  estimate  adjusted  by  ratio  of  assumed  capacity  factor  to  BECO's  assumed  capacity 
factor  of  70%. 

O&M  Costs: 

BECQ:  0.5%  per  year  from  1990 

Optimistic:  2%  real  growth  from  year  when  BECO  projection  crosses  National  Trend  line. 

National  Trp.nd:  Same  as  BECO  to  1990.  Linear  growth  of  $3.6  million  per  year  thereafter  (1986$); 
derived  from  ESRG  equation  applied  to  Pilgrim  characteristics. 

Pcfisimistic; 

Same  as  BECO  to  1990.  Then  linear  growth  of  $4.4  milUon  per  year  (1986$)  per  year  derived  from  linear 

regression  of  Pilgrim  historical  O&M  costs  from  1973  to  1986. 

Present  value  of  O&M  shutdown  costs  is  included  in  present  value  of  year  2012  O&M.  Year  2013  O&M  is 
assumed  to  be  40%  of  prior  year;  20%  for  the  five  years  thereafter.  Based  on  BECO  Exhibit  2. 

Annual  Costs: 

=  Return  +  Income  Tax  +  Depreciation  +  Insurance  +  Local  Tax  +  Decommissioning  +  Fuel  + 
O&M 

Costs  in  Cents  per  Kwh: 

=  Annual  Cost  /  Aimual  Generation 

Annual  Generation  =  Capacity  [670000  Kw]  x  8760  hours/yr.  x  Capacity  Factor 

Capacity  Factor: 

EECQ:70% 

OptimUtir- 

Average  of  seven  BWRs  between  400  -  799  Mw  for  1977-1986 

=  63.159% 


21 


\i 


308 


From  North  American  Electric  Reliability  Coimcil,  Equipment  Availability  Report  1975  -  1986. 

National  Trend: 

56  percent;  derived  from  ESRG  regression  equation  for  Pilgrim  and  equal  to  Pilgrim's  lifetime  capacity 
factor  before  its  shutdown  in  April,  1986. 

Pilgrim  Trend: 

50  percent;  Pilgrim's  lifetime  capacity  factor  as  of  October  1987. 

Incremental  Costs: 

Incremental  cost  comparison  is  BECO's  preferred  way  of  comparing  future  Pilgrim  costs  with  alterna- 
tives. Comparing  Pilgrim  incremental  costs  (which  subtract  shutdown  and  sunk  cost  charges  from  Pilgrim 
total  costs)  to  alternative  costs  is  the  same  as  comparing  Pilgrim  lota!  costs  to  alternative  costs  plus  shut- 
down and  sunk  cost  charges. 

As  in  BECO  Exhibit  2 

=  Anoual  Cost  -  Cost  of  service  on  sunk  costs 

Cost  of  service  on  sunk  costs  includes  return  and  depreciation  (amortization)  on  sunk  costs  as  of  end  of 
1987  (846  million);  plus  O&M  costs  of  $40  milLon  in  1988  and  $20  million  per  year  in  1989-1993;  plus  in- 
surance of  $2.3  million  per  year  1988-1993;  plus  property  taxes  declining  from  $9  million  in  1988  to  $1  mil- 
lion in  1993  and  thereafter;  plus  decommissioning.  In  BECO  Ca.<;e.  S.SO  million  in  nuclear  fuel  and  $20 
million  in  materials  and  suppUes  is  included  in  sunk  cost  rate  base.  In  MASSPIRG  scenarios,  it  is  assumed 
that  64%  of  the  investment  in  fuel  and  supplies  is  sold  to  other  utilities,  and  36%  included  in  rate  base. 

Replacement  Power  Costs: 

Pilgrim  Trend  Case: 

=  Average  Award  Group  Bid;  from  John  Whippen,  Manager,  Energy  Resource  Planning  &  Forecasting, 
Boston  Edison,  Letter  to  RFP  Respondents,  October  13, 1987. 

Natinna]  Trend  Case: 

=  Estimated  average  bid  from  next  764  Mw  supply  block  after  Award  Group. 

=  RFP  Ceiling  Price  -  ((RFP  Ceiling  Price  -  Average  Award  Group  Bid) 

x  ((Average  Supply  Block  Ratepayer  Benefit  Score  -  1)  /  (Average  Award  Group  Ratepayer  Benefit  Score 

-1))) 

The  average  Ratepayer  Benefit  Score  of  the  Award  Group  was  1  Jl;  the  average  Ratepayer  Benefit  Score 

of  the  next  764  Mw  supply  block  was  1.22.  Each  year,  the  supply  block  price  was  assumed  to  capture  22/31 

of  the  benefits  of  the  award  group,  or  70.9%  of  the  difference  between  the  ceiling  price  and  the  Award 

Group. 

RFP  Ceiling  Price  from  John  Whippen,  Letter  to  RFP  Recipient,  February  19, 1987. 
Ratepayer  Benefit  Scores  from  Frank  McCall,  Letter,  October  ,  1987. 


=  Estimated  average  bid  of  the  entire  1327  Mw  of  acceptable  QFs  not  in  the  Award  Group.  Calculated  as 

above.  Average  savings  =  52.4%  of  Award  Group. 

Present  Value: 

The  calculation  of  present  value  of  a  future  cash  stream  discounts  future  cash  flows  to  reflect  the  time 

value  of  money.  A  dollar  in  hand  today  is  worth  more  than  a  dollar  next  year,  by  the  amount  of  interest 

that  could  be  earned  (or  the  interest  payments  that  could  be  deferred)  by  having  the  dollar  for  the  year's 

time. 

Discount  rate  =  10.55%,  from  BECO  Exhibit  1. 


22 


309 


Appendix  B 

MASSPIRG  NUCLEAR  COST  ESTIMATES 


A.  Capital  additions 


Nuclear  plants  have  required  steadily 
increasing  capital  additions  in  order  to 
replace  worn-out  parts  and  meet  new 
safety  standards.  On  average  nuclear  capi- 
tal additions  have  increased  at  13  percent 
a  year  since  1970,  after  adjusting  for  infla- 
tion (Figure  14).  Replacement  of  some 
reactor  parts,  such  as  cracked  pipes  in 
Boiling  Water  Reactors  (BWRs)  like 
Pilgrim,  and  steam  generators  in  Pres- 
surized Water  Reactors  (PWRs),  have  re- 
quired as  much  as  $100  million  or  more 
per  plant. 

Pilgrim  cost  trends  were  analyzed  by  a 
statistical  technique  called  "linear  regres- 
sion analysis."  An  equation  was  deter- 
mined for  the  straight  line  that  best  fits 
Pilgrim's  historical  cost  pattern,  after  ad- 
justing for  the  effects  of  inflation.  To 


23 


measure  national  cost  trends,  this 
report  uses  equations  developed  by  the 
Energy  Systems  Research  Group 
(ESRG),  a  Boston-  based  consulting 
group  that  has  studied  nuclear  costs  for 
numerous  state  regulatory  and  con- 
sumer agencies  around  the  country.' 
ESRG  has  analyzed  nuclear  cost  trends 
using  "multi-variate  regression  analysis" 
~  a  technique  which  relates  changes  in 
nuclear  costs  to  a  number  of  factors 
such  as  plant  type,  size,  location, 
vintage  (in-sen'ice  date),  and  year  of 
operation. 

In  general,  plants  with  Pilgrim's 
characteristics  have  experienced  far 
greater  capital  additions  than  the  na- 
tional average.  BWR  capital  additions 
have  escalated  faster  than  at  PWRs,  for 
instance,  and  salt-water  cooled  plants, 
like  Pilgrim,  have  experienced  more 
capital  additions  than  fresh-water 


Figure  14  Figure  15 

NATIONAL  AVERAGE  CAPITAL  ADDITIONS   PILGRIM  &  NAT  AVG.  CAPITAL  ADDITIONS 


SpConstant  1986  Dollars  per  Kilowatt 


45 

40 

35 

30 

25 

20 

15. 

10. 

5 

0 


/ 


280     Constant  1986  Dollars  per  Kw 
260^ 


/ 
/ 


-1^74r-     1978       1962       1986 
Year 
,   National  Average 


-t97Jr 


978    ■    1982" 


Year 

„   Pilgrim     .    National  Avg. 


ESRG  Regression 


23 


310 


Figure  16 
CAPITAL  ADDITIONS  PROJECTIONS 


Constant  1986  Dollars 


1977   ■   1961        1965  '    1969      1993   '    1997      2001       2005      2009" 

Year 
□      Pilgrim  Historical 


cooled  plants.  ESRG's  regression  analysis 
has  found  that  capital  additions  are  re- 
lated to  plant  size,  type,  cooling  water, 
age,  year  of  in,  lal  operation,  and  whether 
a  plant  has  one  or  two  units  at  a  site. 

Capital  additions  at  the  Pilgrim  plant 
have  been  among  the  highest  of  any  U.S. 
nuclear  plant.  Total  Pilgrim  capital  addi- 


tions over  the  period  of  1972  to  1986 
were  3.3  times  the  national  average  per 
kilowatt,  and  considerably  higher  than 
the  regression  line  for  plants  of  the 
same  characteristics  (Figure  15). 

Figure  16  displays  alternative  projec- 
tions of  future  Pilgrim  capital  addi- 
tions. Except  for  one  moderately 


Figure  17 

CUMULATIVE  SAVINGS  FROM  RETIRING  PILG. 


Sensitivity  to  Capital  Additions 


2000 
Year 
NatTrend 


2012 


PilgTrend 


24 


311 


expensive  repair  planned  for  1990, 
Edison  forecasts  several  years  of  declin- 
ing real  expenses  for  capital  additions,  fol- 
lowed by  a  steady  outlay  of  less  than  $30 
million  a  year  through  the  year  2007. 
Capital  additions  are  estimated  to  decline 
by  20  percent  per  year  over  the  last  five 
years  of  the  plant's  life.  Even  Boston 
Edison  appears  to  have  little  confidence 
in  its  capital  additions  estimates, 
however: 

We  have  provided  a  reasonable  es- 
timate of  Pilgrim's  costs  for  the  next 
25  years.  However,  as  you  know,  many 
factors  external  to  the  company,  such 
as  NRC  mandated  modifications,  can 
significantly  impact  Pilgrim's  Custi." 

MASSPIRG's  optimistic  projection  of 
Pilgrim  capital  additions  starts  with  the  as- 
sumption that  the  four  years  witn  the 
highest  capital  additions  (1980, 1982, 
1984,  1987)  were  caused  by  unique  events 
~  such  as  the  replacement  of  cracked 
recirculation  pipes  in  1984  —  which  will 
not  recur.  The  remaining  years  still  show 
a  consistent  underlying  pattern  of  capital 
additions  increases  which  is  likely  to  per- 
sist into  the  future.  To  be  ultra-  conserva- 
tive, the  Optimistic  Case  here  assumes 
that  this  trend  continues  only  for  another 
five  years.  Capital  additions  are  also  con- 
servatively assumed  to  decrease  over  the 
last  five  years  of  the  plant's  life,  even 
though  other  utilities  have  testified  that  a 
higher  rate  of  capit^il  additions  may  be 
needed  to  keep  them  running.  (See  Ap- 
pendix B.)  Edison's  estimate  for  1990 
capital  additions  is  assumed  to  represent 
a  particular  planned  expenditure  which  is 
included  in  MASSPIRG's  Optimistic 
Case  as  well. 

The  National  Trend  Case  assumes  that 
Pilgrim's  rate  of  capital  additions  declines 
to  the  level  described  by  the  ESRG 
regression  equation,  and  continues  at  that 


rate  for  five  years.  The  Pilgrim  Trend 
case  assumes  that  capital  additions  con- 
tinue at  their  historic  rate  (with  1984 
and  1987  additions  still  defined  as  non- 
recurring costs)  for  10  years. 

Figure  17  illustrates  the  effect  of 
changing  only  the  assumption  about  fu- 
ture capital  additions,  holding  all  other 
BECO  assumptions  the  same.  If 
Pilgrim  capital  additions  were  to  follow 
the  National  Trend  (an  improvement 
from  the  historical  performance  of  the 
plant),  it  would  cost  ratepayers  very  lit- 
tle to  retire  the  plant,  even  assuming 
full  payment  of  Pilgrim  sunk  costs,  in- 
cluding a  profit. 

B.  Operation  and  maintenance 
costs 


Like  nuclear  capital  additions,  opera- 
tion and  maintenance  (O&M)  costs 
have  also  been  increasing  over  time,  at 
an  average  rate  of  1 1.4  percent  a  year 
for  the  nuclear  industry  as  a  whole.  At 
Pilgrim,  total  O&M  costs  have  in- 

Figure  18 

PILGRIM  VS.  NATIONAL  AVG.  O&M  COSTS 


140  Constant  1986  Dollars  per  Kw 


^974      1978 


1962-— raee 


Pilgrim 


Year 
National  Avg._   ESRG  Regression 


25 


312 


Figure  19 
O&M  COST  PROJECTIONS 
Million  Constant  1986$ 


National  >enc! 
rim  Optimistic 


-1988 1893—1998-— 2603- 


Historical 


creased  at  an  annual  rate  of  13.8  percent, 
after  inflation.  Total  Pilgrim  O&M  expen- 
ditures between  1972  and  1986  have  ex- 
ceeded the  national  average  per  kilowatt 
by  78  percent.  Pilgrim  O&M  expenses 
were  less  than  the  regression  line  for 
plants  with  Pilgrim's  characteristics  until 
1983,  however  (Figure  18).  Figure  18  sug- 
gests that  management  decisions  to  defer 
maintenance  in  the  early  years  of  Pilgrim 
operation  may  have  contributed  to  some 
of  the  plant's  later  problems. 


Not  surprisingly.  O&M  cost  in- 
creases are  correlated  with  many  of  the 
same  variables  as  capital  additions  - 
plant  size,  age,  number  of  units  at  a 
site,  and  salt-water  cooling.  After  the 
Three  Mile  Island  Accident  in  1979, 
O&M  costs  increased  at  all  plants  by  an 
average  of  $8.55  per  kilowatt.  In  addi- 
tion, plants  located  in  the  northeast 
have  had  O&M  costs  averaging  about 
$8  per  kilowatt  above  plants  in  other 
regions. 


Figure  20 

CUMULATIVE  SAVINGS  FROM  RETIRING  PILG. 
Sensitivity  to  O&M  Costs 


BECO 


Opt 


■1996- 2000 

NatTrend 


-2004 2008^     2012 

Pilg.Trend 


26 


313 


Figure  21 
HISTORICAL  CAPACITY  FACTORS 
1 .00  Percent 


Pilgrim 


Year. 


National  Avg. 


Alternative  projections  of  O&M  costs 
are  shown  in  Figure  19.  Edison  projects 
substantial  increases  in  O&M  costs  over 
the  next  several  years,  compared  to  both 
Pilgrim  and  national  trends.  A  portion  of 
the  near- term  O&M  costs  also  includes 
replacement  power  costs  during  extended 
Pilgrim  shutdowns  that  customers  are  ex- 
pected to  pay  over  several  years.     After 
1990,  however,  BECO  projects  that  real 
O&M  costs,  like  capital  additions,  will  sta- 


bilize in  constant  dollars,  mcreasing  :u 
only  0.5  percent  per  year. 

The  MASSPIRG  Optimistic  Case 
projects  O&M  costs  increasing  at  only 
two  percent  a  year,  after  adjusting  for 
inflation,  after  1994.  The  National 
Trend  and  Pilgrim  Trend  cases  assume 
that  O&M  costs  eventually  resume 
their  historical  pattern  of  increase. 

Figure  20  displays  the  effect  of 
changing  only  the  O&M  assumption  on 
cumulative  savings  from  retiring 
Pilgrim.  While  significant,  the  overall 
impact  is  not  as  large  as  that  from 
changing  capital  additions  assumptions. 

C.  Capacity  factor 


The  best  measure  of  nuclear  plant 
performance  is  capacity  factor  -  rough- 
ly, the  percentage  of  time  a  plant  is  in- 
service  at  full  power.  The  capacity 
factor  of  a  given  plant  reflects  periods 
that  it  is  shut  down  for  refueling,  main- 
tenance and  repair.  It  also  accounts  for 
times  when  plants  may  be  forced  to 


Figure  22 

CAPACITY  FACTOR  PROJECTIONS 


19*7? 


-Tms 


^f9Kr 


1968  1993 

Year 
2-Year  Rolling  Avg. 


T998- 


2003 


2008^ 


27 


314 


operate  at  reduced  power  levels. 

Capacity  factors  of  individual  nuclear 
plants  tend  to  var>'  a  great  deal  from  year 
to  year,  particularly  since  most  plants  are 
refueled  every  other  year,  and  may  be 
taken  out  of  service  for  several  months 
during  that  time.  Across  the  entire  in- 
dustry, however,  nuclear  capacity  factors 
have  tended  to  average  consistently  just 
under  60  percent.     Pilgrim's  lifetime 
capacity  factor  to  date  is  only  50  percent. 
At  the  point  it  was  shut  down  in  April, 
1986,  the  plant  had  averaged  a  capacity 
factor  of  56  percent  (Figure  21). 

Some  varieties  of  nuclear  plants  have 
averaged  better  performance  than  others. 
Between  1975  and  1985,  for  example. 
Pressurized  Water  Reactors  (PWRs) 
averaged  capacity  factors  of  60.8  percent, 
compared  to  only  56.6  percent  for  Boiling 
Water  Reactors  (BWRs)  Uke  Pilgrim. 
Smaller  plants,  however,  have  generally 
achieved  higher  capacity  factors  than 
larger  plants.  Capacity  factors  of  BWRs 
between  400  Mw  and  799  Mw,  excluding 


the  Pilgrim  plant,  averaged  632  per- 
cent between  1976  and  1986.^^ 

ESRG's  regression  analysis 
describes  capacity  factor  as  a  function 
of  plant  size,  general  type,  type  of  cool- 
ing water  and  steam  system,  and  plant 
age.  It  shows  that  nuclear  plants  have 
generally  tended  to  increase  capacity 
factors  over  their  first  four  yeart  of 
operation,  and  experience  only  flight 
gains  in  performance  over  the  sub- 
sequent eight  years.  Reactors  that  are 
cooled  with  salt  water,  like  Pilgiim. 
have  tended  to  decline  in  perforrnance 
each  year. 

Figure  22  illustrates  ESRG's  regres- 
sion equation  forecast  for  a  plant  of 
Pilgrim's  characteristics,  and  the 
capacity  factor  projections  used  in  the 
three  alternative  Pilgrim  cost  scenarios. 
A  two-year  rolling  average  of  Pilgrim's 
historical  capacity  factor  is  also  s^own 
Averaging  each  year's  capacity  factor 
with  the  previous  year's  helps  to 
smooth  out  the  year-to-year  ups  and 


Figure  23 

CUMUL-ATIVE  SAVINGS  FROM  RETIRING  PILG. 


200 


Sensitivity  to  Capacity  Factor 


wir 


28 


315 


downs  in  capacity  factor  caused  by  refuel- 
ing shutdowns  every  other  year. 

Boston  Edison  assumes  that  Pilgrim 
will  operate  at  a  70  percent  capacity  fac- 
tor over  the  remainder  of  its  life. 
Pilgrim's  lifetime  capacity  factor  of  50 
percent  ranks  79th  among  94  nuclear 
plants.     The  probability  of  Pilgrim 
moving  from  the  bottom  fifth  to  well 
above  the  average  capacity  factor  is  quite 
low,  particularly  in  Ught  of  the  trend  of 
declining  capacity  factors  in  salt-water 
cooled  reactors. 

A  63.2  percent  capacity  factor  -  the  na- 
tional average  for  small  BWRs  excluding 
Pilgrim  -  is  used  in  MASSPIRG's  Op- 
timistic Case.  A  56  percent  capacity  factor 
~  equal  to  Pilgrim's  performance  before 
the  1986  shutdown  and  the  peak  capacity 
factor  predicted  by  the  regression  equa- 
tion -  is  used  in  the  National  Trend  Case. 
Finally,  the  Pilgrim  Trend  case  assumes 
that  the  plant  will  continue  to  average  a 
50  percent  capacity  factor  over  the  rest  of 
its  life.  These  estimates  all  conservatively 


assume  that  the  declining  performance 
of  salt-water  cooled  reactors  shown  by 
ESRG's  regression  equation  will  not 
continue. 

Most  of  the  costs  of  owning  and 
operating  a  nuclear  plant  are  "fixed 
costs"  which  do  not  vary  with  how  much 
electricity  the  plant  actually  produces 
in  a  given  year.  The  iQiai  cost  of  operat- 
ing Pilgrim  over  the  next  25  years  ihere- 
fore  does  not  vary  much  with  capacity 
factor.  A  lower  capacity  factor  means 
that  more  energy  would  have  to  be  pur- 
chased to  replace  Pilgrim,  however, 
and  means  a  higher  cost  for  each  Kwh 
generated  by  Pilgrim. 

Figure  23  illustrates  the  impact  of 
capacity  factor  on  the  economics  of 
retiring  Pilgrim.  Even  if  Pilgrim  were 
able  to  maintain  the  56  percent 
capacity  factor  it  achieved  before  its 
April  1986  shutdown,  it  would  save 
ratepayers  money  through  the  year 
2003  to  retire  the  plant,  even  if  all 
other  BECO  assumptions  hold. 


29 


316 

Appendix  C 

Causes  of  Nuclear  Cost  Escalation 


The  continuing  existence  of  the  factors 
that  have  contributed  to  past  escalation  of 
nuclear  capital  additions  and  operations 
and  maintenance  costs  make  it  likely  that 
those  expenses  will  continue  to  escalate  at 
historic  rates  for  the  foreseeable  future. 
The  forces  driving  the  cost  escalation  in- 
clude the  persistence  of  unresolved  safety 
issues,  ongoing  technical  problems  that 
are  discovered  as  the  nuclear  industry 
gains  more  operating  experience,  and  the 
aging  of  reactor  components.  In  addition 
to  increasing  costs,  premature  aging 
problems  also  cast  serious  doubt  on 
whether  the  Pilgrim  plant  could  be 
operated  for  a  40-year  lifetime,  as  Boston 
Edison  projects. 

1.  Unresolved  generic  safety  issues. 


The  Nuclear  Regulatory  Commission 
maintains  a  list  of  um-esolved  safety  issues 
which  are  generic  to  nuclear  power  reac- 
tors. As  these  issues  are  resolved,  they  fre- 
quently require  significant  new  expenses 
to  implement  them. 

Before  the  1979  accident  at  Three 
Mile  Island  (TMI),  the  NRC  had  resolved 
20  of  142  issues  identified  in  its  1978  Task 
Action  Plan,  according  to  a  1984  General 
Accounting  Office  report.     The  TMI  ac- 
cident added  many  new  issues  to  the 
Commission's  Hst,  and  postponed  action 
on  many  of  the  previously  identified 
problems.  By  July  1984,  the  agency  had 


resolved  only  208  of  482  total  issues 
identified  through  that  time.  Moreover, 
new  issues  were  being  identified  at  the 
rate  of  1 1  per  year,  while  the  agency 's 
schedule  called  for  the  resolution  of 
only  12  total  issues  per  year.  As  of 
August,  1987,  163  issues  remained  on 
the  unresolved  issues  list. 


30 


New  generic  issues  are  likely  to  be 
discovered  as  a  result  of  operating  ex- 
perience, particularly  as  reactors  age. 
The  possibility  of  additional  major 
nuclear  accidents  also  contributes  to 
the  likelihood  of  new  regulations.  The 
NRC  staff  has  estimated  that  the  prob- 
ability of  a  full  core  melt  accident  at  a 
U.S.  nuclear  plant  may  be  as  high  as  45 
percent  during  the  next  20  years. 
Other  analysts  have  estimated  the  prob- 
ability to  be  higher. 

One  unresolved  safety  problem  that 
is  of  particular  concern  to  Pilgrim  is  the 
strength  of  the  containment  shell  which 
is  designed  to  prevent  release  of 
radioactive  materials  to  the  environ- 
ment in  the  event  of  an  accident.  An 
NRC  task  force  has  estimated  that  the 
probability  of  failure  of  the  Mark  I  con- 
tainment design  used  Pilgrim  and  25 
other  U.S.  plants  may  be  as  high  as  90 
percent  in  some  accident  scenarios, 
compared  to  a  failure  probability  of 

about  10  percent  with  other  contain- 

32 
raent  designs. 


30 


317 


Another  commission  task  force  is  cur- 
rently studying  the  Mark  I  problem,  but  is 
not  expected  to  make  recommendations 
for  more  than  a  year.  There  is  a  substan- 
tial probability  that  fixing  the  Mark  I  con- 
tainment problem  will  impose  costs 
exceeding  current  BECO  estimates. 

2.  Ongoing  technical  problems. 


There  is  persistent  evidence  that 
nuclear  technology  has  not  yet  "matured," 
and  that  reactor  operation  will  continue 
to  be  plagued  with  safety-  related  and 
non-safety  related  problems  that  reduce 
capacity  factor  and  require  new  O&M 
and  capital  additions  expenditures  to  fix. 
The  mmiber  of  Licensee  Event  Reports 
(LERs)  --  which  document  mishaps  at 
nuclear  plants  -  has  steadily  increased.  In 
1986,  there  were  2,957  LERs  filed  with 
the  NRC,  approximately  the  same  as  the 
record  2,997  LERs  for  1985,  and  well 
above  the  2,435  LERs  reported  in  1984. 
Nuclear  plant  capacity  factors  have  failed 
to  increase  as  the  nuclear  industry 
predicted  they  would  as  plants  matured. 


33 


3.  Aging  of  reactor  components. 


The  need  to  replace  worn  plant  com- 
ponents and  systems  has  greatly  outpaced 
industry  expectations.  A  1984  NRC  staff 
report  identified  5,893  events  in  safety-re- 
lated systems  occurring  between  1969  and 
1982  (17  percent  of  all  LERs)  as  age-re- 
lated. Additional  aging  problems  have  oc- 
curred in  non-  safety-related  systems. 
Aging  problems  have  been  caused  by 
wear  and  tear,  corrosion,  internal  and  ex- 
ternal radiation  contamination,  contact, 
vibration,  stress  corrosion,  erosion,  and  a 
category  of  miscellaneous  problems. 


As  discussed  in  the  text,  salt-water 
cooling  systems  at  reactors  located  on 
oceans,  such  as  Pilgrim,  have  been  as- 
sociated with  more  corrosion  than 
fresh-water  systems.  In  addition,  the 
Pilgrim  plant  has  been  subject  to  much 
higher  levels  of  radiation  contamina- 
tion that  many  other  nuclear  plants. 
The  average  Pilgrim  worker  was  ex- 
posed to  1949  rem.<;  a  yea'  between 
1984  and  1986,  compared  to  645  rems 
per  year  at  Millstone  I,  in  Connecticut, 
a  plant  the  same  type  and  about  the 
same  age  as  Pilgrim." ' 

4.  Nuclear  plant  lifetimes. 


In  addition  to  causing  mcreasing 
costs  for  replacement  of  parts  and 
operation  and  maintenance  expenses, 
reactor  aging  casts  serious  doubt  on  the 
ability  of  nuclear  plants  to  operate  for 
the  40  year  period  assumed  by  Edison 
in  its  evaluation  of  Pilgrim  economics. 

Boston  Edison's  operating  license 
for  Pilgrim  currently  expires  in  2008, 
after  35  years  of  operation.  The  utility 
has  recently  applied  for  an  extension  of 
its  Hcense  to  the  year  2012.  No  license 
extensions  for  any  nuclear  plants  have 
yet  been  considered  or  granted  by  the 
NRC,  however,  and  there  is  no  way  at 
this  time  of  predicting  whether  such  ex- 
tensions will  be  granted  in  the  future. 

Niagara  Mohawk  Corporation,  the 
chief  owner  and  operator  of  the  Nine 
Mile  Point  1  nuclear  plant,  requested 
permission  from  the  New  York  State 
PubHc  Service  Commission  to  use  a 
depreciation  life  of  the  plant  that  is  five 
yeais  shorter  than  the  plant's  operating 
"cense" 

Recognizing  the  regulatory  pres- 
sures from  the  Nuclear  Regulatory 


31 


318 


Commission,  relicensing  should  not 
be  assumed.  If  it  should  happen  that  it 
is  possible  to  relicense  the  plant,  the 
capital  expenditures  required  would 
be  of  such  a  magnitude  that  the  unit, 
for  depreciation  purposes,  should  be 
considered  as  being  new  at  that 
time.-'^ 

Niagara  Mohawk's  testimony,  in  addi- 
tion to  contradicting  BECO's  assumption 
of  relicensing,  also  contradicts  Edison's 
assumption  that  capital  additions  expendi- 


tures would  not  increase  in  real  terms 
over  the  entire  last  25  years  of  the 
plant's  projected  life,  and  would 
decrease  at  20  percent  per  year  over 
the  last  five  years. 

To  date,  no  conmiercial  nuclear  plant 
has  yet  operated  for  longer  than  27 
years  (Table  4),  and  a  significant  num- 
ber of  reactors  have  been  retired  with 
considerably  fewer  years  of  operation. 
(Table  5) 


TabU  4.  OLDEST  U^.  OPERATING  NUCLEAR  REACTORS 

Plant 

Location 

Initial 

A«e 

Capacity 

Operation 

Yankee 

Rowe,  MA 

1960 

27 

185 

Big  Rock  PoiM 

Charievoix,  Ml 

1962 

25 

75 

San  Onofre  1 

San  aemente,  CA 

1967 

20 

450 

Haddam  Neck 

Haddam  Neck,  CT 

1967 

20 

600 

Oyster  Creek 

Forked  River,  NJ 

1969 

18 

550 

Nine  MUe  Point! 

Scr»ba,NY 

1969 

18 

642 

Gmna 

Ontario,  NY 

1969 

18 

517 

Dresdea  2 

Morris,  IL 

1970 

17 

794 

Robinson  2 

Hartsviile,  SC 

1970 

J7 

769 

Point  Beach  1 

Two  Creeks,  Wl 

1970 

17 

485 

Millstone  I 

Waterford,  CT 

1970 

17 

660 

Sorurce:  Critical  Mass  Energy  Project;^  Nuclear  Regulatory 

Commission 

Table  5.  RETIRED  U.S.  REACTORS 


Plant 


Initial 
Operation 


Retirement 
Year 


32 


Capacity 


Three  Mile  Island  2 

;      ■■     1978 

1979 

1 

906 

Pathfinder 

:>:        1966 

1967 

1 

66 

Haifam 

.:.:    1963 

1964 

1 

256 

Piqua 

1963 

1966 

2 

45 

CVTR 

1963 

1967 

3 

65 

m::    Bonus 

1964 

1968 

4 

50 

={;v      Elk  River 

;<■;     1963 

1968 

4 

22 

Fermi  1 

1966 

1972 

6 

61 

:>:        Peach  Bottom  1 

1967 

1974 

8 

40 

Indian  Point  1 

1962 

1974 

12 

265 

Humboldt  Bay 

1963 

1976 

13 

65 

Dresden  1 

1960 

1978 

19 

207 

319 


Notes 


A  federal  study  estimated  subsidies  for  research  and  development,  mining  and  fuel  enrichment  at  almost 
$40  billion  by  1981.  (Joseph  Bowring,  "Federal  subsidies  to  Nuclear  Power,"  unpublished  report,  Olfic*;  of 
Economic  Analysis,  Energy  Information  Administration,  March  1980.  Another  estimate  of  construction 
subsidies  to  nuclear  power  plants  runs  as  high  as  $15.6  billion  for  the  year  1984  alone.  (H.  Richard  Heede. 
Richard  E.  Morgan,  and  Scott  Ridley,  The  Hidden  Costs  of  Energy:  How  Taxpayers  Subsidize  Energy 
Development,  Center  for  Renewable  Resources,  Washington,  D.C.,  October,  1985) 

^See  Nuclear  Waste  Fee  Adequacy:  An  Assessment,  U.S.  Department  of  Energy,  Office  of  Civilian  Radioac- 
tive Waste  Management,  DOE/RW-  0020,  June  1987,  pp.  7-10;  Commercial  Nuclear  Power:  Prospects  for 
the  United  States  and  the  World,  U.S.  Department  of  Energy/Energy  Information  Administration, 
DOE/EIA-0438(86,  p.  20);  "Nuclear  Power  Plant  Decommissioning:  Cost  Estimation  for  Power  Plaiming 
and  Ratemaking,"  Energy  Systems  Research  Group,  Boston,  July,  1987. 

^Charles  Komanoff,  Power  Plant  Cost  Escalation,  Komanoff  Energy  Associates,  New  York,  1981 . 

^avid  Schlissel,  Trends  for  Nuclear  Capital  Additions  and  O&M  Costs,"  Direct  Testimony  Before  the 
Public  Service  Commission  of  the  State  of  Missouri  Appearing  for  the  Office  of  the  Public  Counsel,  Case 
No.  ER-85-128,  Case  No.  EO-85-185,  June  28, 1985. 

^Nuclear  Plant  Cancellations:  Causes,  Costs  and  Consequences,  U.S.  Department  of  Energy/Energy  Infor- 
mation Administration,  DOE/EIA-0392,  April  1983. 

Schlissel,  op.  cit. 

''  Richard  Hellman  and  Caroline  J.C.  Hellman,  The  Competitive  Economics  of  Nuclear  and  Coal  Power, 
Lexington  Books:  Toronto,  1983. 

^Richard  McCormack,  "Whoops!"  Energy  Daily,  April  28, 1986,  p.  1 

'Joseph  Kricsberg,  Nuclear  Power  Too  Costly  to  Continue,  Draft,  Critiral  Ma«  Energy  Project, 
Washington.  D.C..  November  1987 

Ibid.,  from  U.S.  Department  of  Energy  communication. 

Schlissel,  op.  cit. 

^^illiam  Blundell,  "Doubts  Pervade  Nuclear  Fuel  Industry  Utility  Pacts  Unclear;  Uranium  Producers 
Ailing,"  The  Wall  Street  Journal,  October  10, 1985;  Kennedy  Maize,  'Doraenici's  Uranium  Bill  Would  Trim 
imports  to  50  Percent  of  U.S.  Needs,"  The  Energy  Daily,  February  20, 1986. 

^Power  to  Spare:  A  Plan  for  Increasing  New  England's  Competitiveness  Through  Energy  Efficiency,  New 
England  Energy  Policy  Cotmcil,  July  1987. 

Fvial  Report  of  the  Boston  Edison  Review  Panel,  March  1987. 

^NEPOOL  Forecast  Report  of  Capacity,  Energy,  Loads  and  Transmission  1987-  2002,  New  England  Power 
Pool,  West  Springfield,  MA,  April  1, 1987. 

'^Boston  E^soa,  Request  for  Proposals  from  Qualifying  Cogeneration  and  Small  Power  Production 
Facilities,  Appendix  C,  Exhibit  4,  p.  18. 

^^Final  Report:  Asset  Disposal  and  Contract  Settlement  Associated  With  Pilgrim  2  Cancellation,  Boston 
Edison  Company,  Report  #10,  May,  1987 

^^estem  Massachusetts  Electric  Company,  D.P.U.  84-25. 

^Western  Massachusetts  Electric  Company,  D.P.U.  85-270 

Nuclear  Plant  Cancellations,  op.  cit,  » 


33 


320 


^Harvey  Salgo,  Raymond  Czahar,  and  Paul  Raskin,  TrofKJsal  of  the  Executive  Office  of  Energy  Resour- 
ces, DP.U.  86-36,  April  4,  1986. 

^^quations  for  this  study  were  talcen  from  the  Testimony  of  Stephen  Bemow  on  "Excess  Capacity  and 
Cost  Benefit  Analysis  of  Vogtle  Generating  Station"  on  behalf  of  the  Georgia  Office  of  Consumers'  Utility 
Counsel  before  the  Georgia  Public  Service  Commission,  Docket  No.  3673-U,  August,  1987. 

^Carl  Gustin,  Vice  President,  Corporate  Relations,  Boston  Edison,  Letter  to  Sharon  Pollard,  Secreatary 
of  Energy  Resources,  Commonwealth  of  Massachusetts,  June  8, 1987.  Also  referred  to  as  Exhibit  1.  Ex- 
hibit 2  is  Carl  Gustin  letter  of  July  1, 1987.. 

Gustin,  personal  communication,  October  1987. 

^^ESRG;  Equipment  Availability  Report  1976-1985,  North  American  Electric  ReUability  Council,  Prin- 
ceton, NJ. 

''ibid. 

^rom  Monthly  Operating  Reports  filed  with  the  U.S.  Nuclear  Regulatory  Commission,  courtesy  of 
Stephanie  Murphy,  Nuclear  Information  and  Resource  Service,  Washington,  D.C. 

^Management  Weaknesses  Affect  Nuclear  Regulatory  Commission  Efforts  to  Address  Safety  Issues 
Common  to  Nuclear  Power  Plants,"  General  Accounting  Office,  GAO/RCED-84-19,  September  19, 
1984). 

^""Efforts  to  Ensure  Nuclear  Power  Plant  Safety  Can  Be  Strengthened,"  General  Accounting  Office, 
GAO/RCED-87-141,  August,  1987. 

"  NRC  Testimony  to  U.S.  House  of  Representatives,  Subcommittee  on  Energy  Conservation  and  Power, 
April  1986. 

Brian  Jordan,  "Denton  Urges  Industry  to  Settle  Doubts  About  Mark  1  ContJiinmenl,"  Inside  N-R-C, 
June  9, 1986,  p.  1. 

^^Joshua  Gordon,  1986  Nuclear  Power  Safety  Report,  Public  Citizen,  Washington,  DC,  September  1987. 

Survey  of  Operating  Experience  from  LERs  to  Identify  Aging  Trends,  Status  Report,"  Nuclear 
Regulatory  Commission,  NUREG/CR-3543,  January  1984. 

David  Wesscl,  "Pilgrim  and  Millstone,  Two  Nuclear  Plants,  Have  Disparate  Fates,"  The  Wail  Street  Jour- 
nal, My  78, 1981.,  p.  I. 

John  S.  Ferguson,  Prepared  testimony  on  behalf  of  the  Niagara  Mohawk  Power  Corporation  in  New 
York  Public  Service  Commission  Case  #28225,  p.  27. 


34 


321 

The  Chairman.  In  one  of  the  reports  you  talked  about  the  sub- 
ject of  advance  pubhc  information  and  education.  And  there  are 
some  that  would  say  that  those  people  claim  not  to  know  the  evac- 
uation procedures,  that  they  are  against  the  plan  anyway,  so  it  is 
not  their  interest  to  be  helpful;  that  it  is  not  in  their  interest  to  tell 
you,  even  if  they  read  the  plan,  that  they  had  read  the  plan,  if  they 
thought  they  would  be  helpful  to  Boston  Edison.  How  do  you  re- 
spond to  that  criticism?  That  is  a  criticism  that  may  be  made. 

Ms.  Shimshak.  Having  participated  in  a  survey,  people  gave  us 
very  honest  answers.  I  believe  that  they  told  you  the  truth  when 
they  said  they  didn't  really  know  what  to  do  in  the  event  of  an 
emergency  and  they  said  they  hadn't  actually  received  the  emer- 
gency information  booklet  in  the  mail. 

One  thing  that  did  stand  out  with  people's  answer  to  these  ques- 
tions is  an  air  of  cynicism.  Having  been  through  15  years  worth  of 
history  of  this  plant,  and  seeing  how  many  problems  it  has  and  ex- 
periencing the  NRC's  lack  of  attention  to  those  plans — those  prob- 
lems, I  think  people  have  a  very  cynical  view.  And  even  if  they 
were  given  proper  instructions,  my  guess  is  they  wouldn't  follow 
them.  They'll  get  together  with  their  families  because  that's  what's 
most  important  to  them  and  they'll  do  what  they  think  is  best  at 
the  moment,  and  I  don't  believe  that  that  will  be  following  the  pre- 
scribed directions. 

The  Chairman.  Are  you,  from  your  own  perspective,  optimistic 
or  pessimistic  as  to  whether  that  plant  will  restart? 

Ms.  Shimshak.  Well,  I  would  be  tempted  to  say  that  I'm  pessimis- 
tic just  because  of  the  NRC's  record  in  the  past,  and  given  the  fact 
that  they  never  really  shut  a  plant  down  for  being  £is  bad  as  Pil- 
grim is.  But  I  must  admit,  I'm  feeling  optimism  for  two  reasons, 
and  one  is  that  you've  taken  an  interest  in  this  plant,  as  well  as 
many  other  elected  officials,  and,  hopefully,  that  will  stimulate 
some  good  action  on  this;  and  also  since  the  plant  has  been  shut 
down  for  21  months,  which  I  don't  believe  any  of  us  would  have 
expected  in  1986  when  it  originally  closed  down. 

The  Chairman.  Thank  you  very  much— you're  a  very  helpful 
panel,  these  are  helpful  reports.  Wish  we  had  more  time  to  go  into 
the  issues.  I  may  want  to  submit  some  more  questions  to  you,  but 
we  appreciate  the  time.  We  are  very  much  impressed — but  not  sur- 
prised— by  the  quality  of  the  representation  of  the  member  of  the 
great  general  court,  the  State  Senate.  By  your  testimony  obvious- 
ly— as  well  as  Mr.  Malaguti's  testimony,  and  the  very  exemplary 
work  that  has  been  done.  I  want  to  thank  all  of  you  very  much. 

[One-minute  break.] 

The  Chairman.  I  want  to  announce  for  the  record,  we  were  not 
able  to  include  all  the  State  Representatives  and  Senators  in  the 
course  of  our  hearing.  We  had  about  10  or  12  that  had  made  appli- 
cations. We  want  to  indicate  to  any  of  those  that  want  to  have 
their  statements  made  a  part  of  the  record,  including  the  State  sen- 
ator that  represents  the  local  community  that  we  will  include 
them. 

We  tried  to  get  the  State  representative,  the  Board  of  Selectmen 
and  the  chairman  of  the  Energy  Committee  in  the  Great  General 
Court.  But  we  want  to  indicate  to  everyone,  if  they  want  their 
statement  included  in  the  record,  we  will  keep  the  record  open.  But 


322 

it  was  really  a  question  of  trying  to  hear  from  as  many  of  the  dif- 
ferent representatives  who  have  interest  and  responsibilities  in  the 
local  community,  from  the  local  representatives  as  well  as  the  rep- 
resentatives of  the  NRC. 

We  wanted  to  hear  all  of  them  and  not  to  try  to  go  below  a  3  or  4 
minutes  presentation;  otherwise,  you  lose  the  real  context  of  the 
hearing.  So  those  are  the  reasons,  quite  frankly.  We  were  not  in- 
tending to  be  disrespectful  to  any  of  those  persons. 

We  are  particularly  delighted  now  to  have  here  an  old  friend  of 
mine,  and  one  of  our  very  fine  public  servants,  the  Lieutenant  Gov- 
ernor of  our  State,  Evelyn  Murphy.  I  welcome  her  to  our  hearing 
as  the  second  ranking  State  official  in  a  position  of  responsibility  in 
the  State  for  its  health  and  well  being,  as  she  brings  a  special  per- 
spective to  this  hearing,  and  we  very  much  look  forward  to  her  tes- 
timony. I'll  ask  that  you  be  good  enough  to  stand  and  take  the 
oath. 

[Lieutenant  Governor  Murphy  sworn.] 

STATEMENT  OF  LT.  GOV.  EVELYN  MURPHY 

Lieutenant  Governor  Murphy.  Thank  you  Senator  Kennedy.  I 
want  to  thank  you  for  giving  all  of  us  the  opportunity  to  come  here 
tonight  and  discuss  the  Pilgrim  nuclear  power  plant  and  the  seri- 
ous public  health  and  safety  questions  surrounding  it.  And  you've 
seen  the  turnout  tonight  on  one  of  the  coldest  nights  of  this  winter, 
it  is  the  testimony  to  the  intense  feelings  that  people  have  about 
the  issue. 

I  come  here  tonight,  not  just  as  Lieutenant  Governor,  but  as  the 
Acting  Governor  to  express  the  Governor's  and  my  concern  about 
the  threat  to  the  public's  health  and  safety  of  this  plant,  and  insist 
on  behalf  of  the  people  of  the  Commonwealth  of  Massachusetts 
upon  two  very  reasonable  specific  actions. 

First  that  the  NRC  hold  an  adjudicatory  hearing  in  Plymouth 
before  this  plant  opens;  and  second,  that  Pilgrim  not  be  allowed  to 
reopen  until  the  emergency  evacuation  concerns  of  both  FEMA  and 
Governor  Dukakis  have  been  satisfactorily  resolved. 

In  June  of  1986,  the  plant  was  closed  because  of  serious  charges 
concerning  the  safety  of  the  management  facility.  I  won't  dwell  on 
the  specifics.  You  are  going  to  hear  from  a  panel  of  State  officials 
here  tonight:  Mr.  Agnes,  the  Assistant  Secretary  of  Public  Safety; 
Commissioner  of  Public  Health,  Deborah  Prothrow-Smith;  Attorney 
General;  Secretary  Pollard,  all  prepared  to  supply  in  detail  from 
the  State's  perspective,  the  concerns  that  Governor  Dukakis  and  I 
share. 

Since  the  closing  of  this  facility.  Governor  Dukakis  has  laid  out 
three  preconditions  for  its  reopening.  Public  health  and  safety  are 
the  crux  of  these  criteria.  First,  the  inadequate  safety  practices  at 
the  plant  must  be  corrected;  second,  the  management  problems 
must  be  resolved,  and  third,  the  evacuation  plan  must  be  adequate. 
These  three  criteria  have  been  offered  as  reasonable  demands  for 
the  operation  of  the  nuclear  power  plant  in  a  heavily  populated 
area.  They  have  not  yet  been  met  by  Boston  Edison. 

This  administration  has  the  responsibility  to  protect  our  citizens. 
And  our  insistence  that  the  plants  be  operated  with  protection  of 


323 

people's  health  and  safety  as  the  foremost  guarantee  is  absolutely 
non-negotiable. 

My  own  reservations  about  this  plant  and  nuclear  power  date 
back  to  1975  when  I  rejected  the  draft  Environmental  Impact 
Report  for  Pilgrim  2.  At  that  time  the  comments  were  on  the  ques- 
tions of  disposal  of  waste  and  about  plant  safety.  Those  issues  are 
the  same,  and  remain  unanswered  today.  So  my  reservations  have 
become  more  resolutions:  the  resolve  to  prevent  our  safety  and  eco- 
nomic health  from  being  held  hostage  to  any  one  power  source;  and 
the  resolution  to  work  toward  the  development  of  safe,  reliable, 
non-nuclear  energy. 

As  you  deliberate  here  tonight  on  the  future  of  the  Pilgrim 
plant,  please  disregard  the  issues  involved  in  supply  and  demand 
on  the  New  England  power  grid.  Let  me  be  very  clear.  We  have 
sufficient  energy  generating  capacity  for  all  but  the  most  unusual 
situations  today.  As  a  matter  of  fact,  Tuesday  night,  demand  hit  a 
record-breaking  peak  of  18,471  megawatts,  that  was  met  through 
contingency  purchases  and  other  standard  operating  procedures, 
once  we  hit  those  contingency  plans.  So  meeting  even  high  electric- 
ity demands  is  possible  without  Pilgrim,  without  Seabrook  and 
without  a  crisis. 

Today's  problems  of  tight  energy  in  New  England  are  more  due 
to  the  lack  of  judicious  management  and  maintenance  practices,  as 
well  as  the  needs  of  aggressive  action  on  short  term  augmentation 
of  supplies,  as  was  just  discussed  by  the  panel;  some  of  the  small 
scale  power  that  could  be  brought  on  line  quickly,  and  some  of  the 
energy  conservation  load  management  practices  that  have  certain- 
ly been  recommended  and  are  possible. 

In  recent  months,  the  State  has  been  very  active  to  do  this,  and 
we're  pulling  together  a  task  force,  at  the  Governor's  request,  so 
the  state  can  move  aggressively  on  these  initiatives  to  augment 
supply  and  dampen  demand.  So  we  are  doing  that.  And  I  would 
only  say  to  you  that  I  would  hold  that  question  about  the  New  Eng- 
land power  supply  aside.  It  has  no  relevancy  whatsoever  tonight. 

Having  expressed  these  concerns  to  you,  I  must  say  that  I  realize 
how  difficult  it  is  for  you.  Governor  Dukakis,  me  and  other  respon- 
sible public  officials  to  make  any  headway  against  an  unresponsive 
Federal  bureaucracy,  which  actually  doesn't  seem  to  care  about  the 
health  and  safety  of  the  citizens  of  the  State. 

It  seems  to  me  that  the  NRC  has  been  surprisingly  nonrespon- 
sive  to  date.  Let  me  be  more  specific,  and  go  through  a  little  bit  of 
the  sequence  here.  In  July  of  1986,  as  Senator  Golden  mentioned,  I 
joined  him,  MASSPIRG,  and  many  other  in  signing  that  show 
cause  petition  for  addressing  three  points  on  nuclear  reactor  safety, 
emergency  planning  and  maintenance.  The  NRC  rather  callously 
dismissed  the  first  two  and  deferred  consideration  on  the  third 
point.  MASSPIRG  appealed  denials,  and  Attorney  General  Shan- 
non, who  is  about  to  testify  after  me,  is  now  an  intervener  in  those 
appeals.  And  yet  there  has  been  no  response.  I  find  this  difficult  to 
accept. 

In  October  of  1987,  Governor  Dukakis  and  Attorney  General 
Shannon  filed  a  show  cause  petition  asking  for  the  adjudicatory 
hearings  on  whether  this  plant  should  be  allowed  to  reopen.  There 
has  been  no  response.  Nor  has  the  NRC  responded  to  a  substan- 


324 

live — in  a  substantive  manner — to  the  two  reports  on  Pilgrim  pre- 
pared by  Secretary  of  Public  Safety  Charles  Barry,  and  submitted 
by  Governor  Dukakis  at  first  on  December  1,  1986;  the  second  De- 
cember of  1987.  And  it  is  now  my  understanding,  Senator,  you  and 
Congressman  Studds  also  submitted  a  request  that  has  been  denied 
in  term  of  appeal  to  an  adjudicatory  hearing. 

NRC  has  indicated  that  it  will  meet  with  petitioners,  and  this,  I 
believe,  for  all  of  us  is  unacceptable.  Citizens  of  the  State  have  a 
right  to  see  this  case  argued  in  a  formal  setting.  I  would  encourage 
you  to  do  everj^hing  in  your  power  to  see  that  this  hearing  takes 
place.  You  have  my  commitment  and  the  Governor's  commitment 
to  fully  support  your  efforts. 

What  the  Governor  and  the  people  of  Massachusetts  have  put 
before  the  NRC,  we  believe  to  be  specific  and  reasonable  requests, 
but  when  confronted  by  bureaucratic  stonewalling,  that  reasonable- 
ness is  likely  to  turn  out  to  be  more  increasing  outrage. 

In  closing,  let  me  make  one  final  point  regarding  FEMA  and  the 
NRC.  As  you  know,  currently  FEMA's  role  is  strictly  advisory.  This 
has  been  mentioned  several  times.  The  situation  here  is  a  prime 
example  of  how  the  NRC  could  overrule  the  recommendations  of 
both  the  Governor  and  FEMA,  as  it's  own  advisory  body.  This  is 
absurd. 

The  Governor  and  I  would  wholeheartedly  support  any  congres- 
sional action  that  you  would  take  in  passing  a  requirement  that 
the  NRC  be  bound  by  the  recommendations  of  the  State  govern- 
ment and  of  FEMA.  For  Massachusetts,  that  would  mean  that  Pil- 
grim would  not  restart  until  the  people  of  Massachusetts  were  sat- 
isfied with  the  emergency  plan. 

We  thank  you  once  again  for  doing  this  tonight  and  for  your  in- 
volvement and  we're  really  quite  grateful. 

[The  prepared  statement  of  Lieutenant  Governor  Murphy  fol- 
lows:] 


325 


EVELYN    F    MURPHY 
LIEUTENANT   GOVERNOR 


THE  COMMONWEALTH   OF   MASSACHUSETTS 
EXECUTIVE    DEPARTMENT 

STATE   HOUSE  •  BOSTON   02133 


ROOM  259 
(617)  727-7200 


TESTIMONY  OF  LIEUTENANT  GOVERNOR  EVELYN  F.  MURPHY 

UNITED  STATES  LABOR  AND  HUMAN  RESOURCES  COMMITTEE 

JANUARY  7 ,  1988 

SENATOR  KENNEDY,  MEMBERS  OF  THE  COMMITTEE.   I  WANT  TO  THANK 
YOU  FOR  GIVING  US  ALL  THE  OPPORTUNITY  TO  COME  HERE  TONIGHT  TO 
DISCUSS  THE  PILGRIM  NUCLEAR  POWER  PLANT  AND  THE  SERIOUS  PUBLIC 
HEALTH  AND  SAFETY  ISSUES  SURROUNDING  IT. 

THE  TURNOUT  TONIGHT,  ON  ONE  OF  THE  COLDEST  NIGHTS  OF  THE 
WINTER,  IS  TESTIMONY  TO  THE  FEELINGS  PEOPLE  HAVE  ABOUT  THIS 
ISSUE. 

I  COME  HERE  TONIGHT  AS  ACTING  GOVERNOR  TO  EXPRESS  THE 
GOVERNOR'S  AND  MY  CONCERNS  ABOUT  THE  THREATS  TO  PUBLIC  HEALTH 
AND  SAFETY  POSED  BY  THIS  PLANT,  AND  TO  INSIST,  ON  BEHALF  OF  THE 
PEOPLE  OF  THE  COMMONWEALTH  OF  MASSACHUSETTS,  UPON  TWO  VERY 
REASONABLE,  SPECIFIC  ACTIONS.   FIRST,  THAT  THE  NRC  HOLD  AN 
ADJUDICATORY  HEARING  HERE,  IN  PLYMOUTH,  BEFORE  THIS  PLANT 
OPENS.   SECOND,  THAT  PILGRIM  NOT  BE  ALLOWED  TO  REOPEN  UNTIL  THE 
EMERGENCY  EVACUATION  CONCERNS  OF  BOTH  FEMA  AND  GOVERNOR  DUKAKIS 
HAVE  BEEN  SATISFACTORILY  RESOLVED. 


326 


IN  JUNE  1986,  THE  NRC  AND  BOSTON  EDISON  ANNOUNCED  THE 
TEMPORARY  CLOSING  OF  THE  PILGRIM  PLANT,  BECAUSE  OF  SERIOUS 
CHARGES  CONCERNING  THE  SAFETY  AND  MANAGEMENT  OF  THE  FACILITY.   I 
WILL  NOT  DWELL  ON  THE  SPECIFICS  OF  THIS  MATTER.   MR.  AGNES,  THE 
ASSISTANT  SECRETARY  OF  PUBLIC  SAFETY  AND  DR.  PROTHROW-STITH ,  THE 
COMMISSIONER  OF  PUBLIC  HEALTH,  ARE  PREPARED  TO  PROVIDE  DETAILED 
DOCUMENTATION  TO  YOU  AND  THE  COMMITTEE  ABOUT  THE  CONCERNS 
GOVERNOR  DUKAKIS  AND  I  SHARE. 

SINCE  THE  CLOSING  OF  THE  FACILITY,  GOVERNOR  DUKAKIS  HAS 
LAID  OUT  THREE  PRECONDITIONS  FOR  ITS  REOPENING;  PUBLIC  HEALTH 
AND  SAFETY  fi^E   AT  THE  CRUX  OF  THOSE  CRITERIA. 

FIRST,  THE  INADEQUATE  SAFETY  PRACTICES  AT  THE  PLANT  MUST  BE 
CORRECTED;  SECOND,  THE  MANAGEMENT  PROBLEMS  MUST  BE  RESOLVED;  AND 
THIRD,  THE  EVACUATION  PLAN  MUST  BE  ADEQUATE. 

THESE  THREE  CRITERIA  HAVE  BEEN  OFFERED  AS  REASONABLE 
DEMANDS  FOR  THE  OPERATION  OF  A  NUCLEAR  POWER  PLANT  IN  A 
HEAVILY-POPULATED  AREA.   AND  THESE  THREE  CRITERIA  HAVE  NOT  YET 
BEEN  MET  BY  BOSTON  EDISON.   THIS  ADMINISTRATION  HAS  THE 
RESPONSIBILITY  TO  PROTECT  OUR  CITIZENS.   OUR  INSISTENCE  THAT  THE 
PLANT  BE  OPERATED  WITH  PROTECTION  OF  PEOPLE'S  HEALTH  AND  SAFETY 
AS  THE  FOREMOST  GUARANTEE  IS  ABSOLUTELY  NON- NEGOTIABLE . . 


327 


t-IY  OWN  RESERVATIONS  ABOUT  PILGRIM  AND  NUCLEAR  POWER  IN 
GENERAL,  DATE  BACK  TO  1975,  WHEN  I  SERVED  AS  SECRETARY  OF 
ENVIRONMENTAL  AFFAIRS  IN  THE  FIRST  DUKAKIS  ADMINISTRATION.   AT 
THAT  TIME,  I  REJECTED  THE  DRAFT  ENVIRONt'lENTAL  IMPACT  REPORT  FOR 
PILGRIM  II  BECAUSE  OF  UNRESOLVED  WASTE  DISPOSAL  PROBLEMS  AND 
QUESTIONS  ABOUT  PLANT  SAFETY.   THESE  ISSUES  REMAIN  UNRESOLVED  TO 
THIS  DAY. 

SO,  MY  RESERVATIONS  HAVE  BECOME  RESOLUTIONS:  RESOLUTION  TO 
PREVENT  OUR  SAFETY  AND  ECONOMIC  HEALTH  BEING  HELD  HOSTAGE  TO  ANY 
ONE  POWER  SOURCE;  AND  RESOLUTION  TO  WORK  TOWARD  THE  DEVELOPMENT 
OF  SAFE,  RELIABLE,  NON-NUCLEAR  ENERGY. 

AS  YOU  DELIBERATE  ON  THE  FUTURE  OF  THE  PILGRIM  PLANT, 
PLEASE  DISREGARD  THE  ISSUES  INVOLVING  SUPPLY  AND  DEMAND  ON  THE 
NEW  ENGLAND  POWER  GRID.   LET  ME  BE  VERY  CLEAR:  WE  HAVE 
SUFFICIENT  ENERGY  GENERATING  CAPACITY  FOR  ALL  BUT  THE  MOST 
UNUSUAL  SITUATIONS.   AS  A  MATTER  OF  FACT,  TUESDAY  NIGHT,  DEMAND 
HIT  A  RECORD-BREAKING  PEAK  OF  18,471  MW,  AND  WAS  MET  THROUGH 
CONTINGENCY  PURCHASES  AND  OTHER  STANDARD  OPERATING  PROCEDLTRES. 
SO,  MEETING  EVEN  UNUSUALLY  HIGH  ELECTRICITY  DEMANDS  IS  POSSIBLE 
WITHOUT  PILGRIM,  WITHOUT  SEABROOK,  AND  WITHOUT  CRISIS. 

TODAY'S  PROBLEMS  OF  TIGHT  ENERGY  IN  NEW  ENGLAND  DERIVE  FROM 
LACK  OF  JUDICIOUS  MAINTENANCE  SCHEDULING  AND  PRACTICE;  A  LACK  OF 
AGGRESSIVE  PERFORMANCE  TO  EASE  DEMAND  THROUGH  CONSERVATION  AND 
LOAD  MANAGEMENT:  AND  A  LACK  OF  STRONG  PURSUIT  OF  SMALL  SCALE 
POWER  PLANTS  TO  AUGMENT  SUPPLY. 


328 


IN  RECENT  MONTHS  THE  STATE  HAS  BEEN  VERY  ACTIVE.   THE 
GOVERNOR  HAS  ASKED  ME  TO  WORK  WITH  SECRETARY  POLLARD,  SECRETARY 
GOLD,  SECRETARY  HOYTE ,  THE  DEPARTMENT  OF  PUBLIC  UTILITIES,  THE 
DEPARTMENT  OF  CAPITAL  PLANNING  AND  OPEPvATIONS  AND  THE  GOVEPJ^OR'S 
ECONOMIC  DEVELOPMENT  OFFICE  SO  THE  STATE  CAN  MOVE  AGGRESSIVELY 
ON  THESE  INITIATIVES  TO  AUGMENT  SUPPLY  AND  DANfPEN  DEMAND.   AND 
WE  ARE  DOING  JUST  THAT. 

HAVING  EXPRESSED  THESE  CONCERNS  TO  YOU,  SENATOR,  I  MUST  SAY 
I  REALIZE  HOW  DIFFICULT  IT  IS  FOR  YOU,  GOVERNOR  DUKAKIS,  ME  AND 
OTHER  RESPONSIBLE  PUBLIC  OFFICIALS  TO  MAKE  ANY  HEADWAY  AGAINST 
AN  UNRESPONSIVE  FEDERAL  BUREAUCRACY,  A  BUREAUCRACY  THAT  REALLY 
DOESN'T  SEEM  TO  CARE  ABOUT  THE  HEALTH  AND  SAFETY  OF  THE  CITIZENS 
OF  THIS  STATE.   IT  SEEMS  TO  ME  THAT  THE  NUCLEAR  REGULATORY 
COMt'lISSION  HAS  BEEN  SURPRISINGLY  NON-RESPONSIVE  IN  DEALING  WITH 
THE  MASSACHUSETTS  GOVERNMENT  AND  THE  PUBLIC  ABOUT  THIS 
FACILITY. 

LET  ME  BE  SPECIFIC.   IN  JULY  OF  1986,  I  JOINED  SENATOR 
WILLIAM  GOLDEN,  MASSPIRG  AND  MANY  OTHERS  IN  SIGNING  A  SHOW  CAUSE 
PETITION  ADDRESSING  THREE  POINTS:  REACTOR  SAFETY;  EMERGENCY 
PLANNING;  AND  MAINTENANCE.   THE  NRC  RATHER  CALLOUSLY  DISMISSED 
THE  FIRST  TWO,  AND  DEFERRED  CONSIDERATION  OF  THE  THIRD  POINT. 
MASSPIRG  HAS  APPEALED  THE  DENIALS,  AND  ATTORNEY  GENERAL  JAMES 
SHANNON  IS  NOW  AN  INTERVENER  IN  THE  APPEAL;  YET  THERE  HAS  BEEN 
NO  RESPONSE.   I  FIND  THIS  VERY  DIFFICULT  TO  ACCEPT. 


329 


IN  OCTOBER,  1987,  GOVERNOR  DUKAKIS  AND  ATTORNEY  GENERAL 

JAMES  SHANNON  FILED  A  SHOW  CAUSE  PETITION  ASKING  FOR  AN 

ADJUDICATORY  HEARING  ON  WHETHER  THIS  PLANT  SHOULD  BE  ALLOWED  TO 
REOPEN.   THERE  HAS  BEEN  NO  RESPONSE. 

NOR  HAS  THE  NRC  RESPONDED  IN  A  SUBSTANTIVE  MANNER  TO  THE 
TWO  REPORTS  ON  PILGRIM,  PREPARED  BY  SECRETARY  OF  PUBLIC  SAFETY 
CHARLES  BARRY  AND  SUBMITTED  BY  GOVERNOR  DUKAKIS,  THE  FIRST  IN 
DECEMBER  1986,  THE  SECOND  IN  DECEMBER  1987. 

AND,  SENATOR,  I  UNDERSTAND  THAT  THE  NRC  HAS  DENIED  THE 
REQUEST  WHICH  YOU  AND  CONGRESSMAN  GERRY  STUDDS  SUBMITTED  ASKING 
FOR  AN  ADJUDICATORY  HEARING  ON  PILGRIM. 

THE  NRC  HAS  INDICATED  THAT  IT  WILL  MEET  WITH  THE 
PETITIONERS.   THIS  IS  UNACCEPTABLE.   THE  CITIZENS  OF  THIS  STATE 
HAVE  THE  RIGHT  TO  SEE  THIS  CASE  ARGUED  IN  A  FORMAL  SETTING.   I 
WOULD  ENCOURAGE  YOU,  SENATOR,  TO  DO  EVERYTHING  IN  YOUR  P0\7ER  TO 
SEE  THAT  THIS  HEARING  TAKES  PLACE.   YOU  WILL  HAVE  THE  GOVERNOR'S 
AND  MY  FULL  SUPPORT  IN  YOUR  EFFORTS. 

WHAT  THE  GOVERNOR  AND  THE  PEOPLE  OF  MASSACHUSETTS  HAVE  PUT 
FORTH  ARE  SPECIFIC  AND  REASONABLE  REQUESTS  AND  SUGGESTIONS.   BUT 
WHEN  CONFRONTED  BY  SUCH  BUREAUCRATIC  STONEWALLING,  A  VOICE  OF 
REASON  COULD  BECOME  TRANSFORMED  INTO  A  VOICE  OF  OUTRAGE.   IT  IS 
AN  UNCONSCIONABLE  ATTITUDE  ON  THE  PART  OF  A  PUBLIC  AGENCY 
SUPPOSEDLY  CHARGED  WITH  PROTECTING  PUBLIC  HEALTH  AND  SAFETY. 


330 


IN  CLOSING,  LET  ME  MAKE  ONE  FINAL  POINT  REGARDING  FEMA  AND 
THE  NRG.   AS  YOU  KNOW,  CURRENTLY  FEMA ' S  ROLE  IS  STRICTLY 
ADVISORY.   HOWEVER,  THE  SITUATION  HERE  IS  A  PRIME  EXAMPLE  OF  HOW 
THE  NRC  COULD  OVERRULE  THE  RECOMMENDATIONS  OF  BOTH  THE  GOVERNOR 
OF  A  STATE  AND  ITS  OWN  ADVISORY  BODY  BY  ALLOWING  PILGRIM  TO 
REOPEN  DESPITE  FJCPERT  OPINION  TO  THE  CONTRARY.   THIS  IS  AN 
ABSURDITY.   THE  GOVERNOR  AND  I  WOULD  WHOLEHEARTEDLY  SUPPORT  ANY 
CONGRESSIONAL  EFFORT  TO  GET  LEGISLATION  PASSED  WHICH  WOULD 
REQUIRE  THE  NRC  TO  BE  BOUND  BY  THE  RECOMMENDATIONS  OF  A  GOVERNOR 
AND  FEMA. 

FOR  MASSACHUSETTS,  THIS  WOULD  MEAN  THAT  PILGRIM  WOULD  NOT 
RESTART  UNTIL  THE  PEOPLE  OF  MASSACHUSETTS  WERE  SATISFIED  WITH 
THE  EMERGENCY  PLANS. 

THANK  YOU. 


331 

The  Chairman.  Thank  you  very  much.  We're  grateful  for  your 
presence  here,  for  your  taking  the  time. 

(Let  me  ask  you.  Given  the  Governor's  position  on  the  Seabrook 
amt  on  the  Pilgrim,  what  is  the  implication,  due  to  the  fact  that 
nuclear  power  provides  some  33  percent  of  the  power  resources  for 
New  England,  if  Seabrook  isn't  opened  and  Pilgrim  is  not  re- 
opened, what  are  the  energy  implications  going  to  be  in  terms  of 
Massachusetts,  and  responding  first  of  all,  and  then  respond  to  the 
point  that  the  legislators  made  in  terms  of  increasing  pressures  in 
term  of  the  growth  in  the  future.  How  are  we  going  to  deal  with  it? 

Lieutenant  Governor  Murphy.  Well,  I  think  those  matters  go 
hand  in  hand.  We  have  right  now  sufficient  energy  on  the  power 
grid  to  respond  to  even  the  most  extreme  matters  that  we  see  right 
now,  for  instance  that  we  had  this  summer. 

The  real  issues  before  us  are  how  to  move  now  to  augment  our 
supply.  There  are  lots  of  proposed  plants  for  small  scale  cogenera- 
tion,  hydroelectric,  environmentally  sound,  small  scale  plants  now 
in  the  licensing  proceedings  within  the  State  government — we  are 
looking  to  expedite  those.  There  is  the  equivalent  of  one  Pilgrim 
plant  right  now  within  that  licensing  procedure.  So  we  can  see 
ways  in  the  short  term  to  augment  supplies.  I  think  we  can  also 
see  ways  in  the  short  term  to  dampen  some  of  the  demands,  conser- 
vation and  load  management  procedures,  and  also  to  take  some 
action  which  even  includes  the  planning,  which  we  have  been 
doing  the  last  couple  of  days,  to  ask  the  utility  companies  to  get 
more  aggressive  concerning  interrupting  rate  contracts. 

So  in  the  short  term.  Senator,  we  believe  very  strongly  that  there 
is  sufficient  power  for  not  only  meeting  today's  demands,  but  in  the 
short-term  summer  growth.  Over  the  longer  trek,  there  is  no  doubt 
that  in  the  mid  1990's,  the  Federal  Reserve  Board  study  is  a  wise 
and  sound  one,  and  that  we'll  need  to  look  at  some  larger  scaled 
plants  to  be  brought  on  line.  That  explains  some  of  the  Governor's 
initiatives  around  natural  gas,  and  the  initiatives  right  now  to  look 
at  increased  resources  from  HydroQuebec,  and  our  looking  at  even 
Edgar  Station. 

So  we  see  a  way  right  now  of  moving  from  the  overreliance  of 
nuclear  power  to  other  options,  diversifying  what  we  have  for  all  of 
New  England  power,  which  makes  us  feel  safer  and  insures  the 
kind  of  reliabilities,  so  that  we  can  continue  to  have  a  sustained 
economic  growth  and  the  jobs  that  we  now  enjoy,  but  it  means  get- 
ting on  with  this.  And  I  think  the  faster  we  can  put  to  rest  the  con- 
troversies of  nuclear  power  and  all  the  other  options,  the  healthier 
and  safer  and  more  reliable  our  energy  sources  are  going  to  be. 

The  Chairman.  I  thank  you  very  much.  I  think  in  your  summa- 
tion of  the  three  major  criteria  which  are  necessary  before  you  and 
the  Governor  will  support  an  opening  of  the  plant,  you  have  cap- 
sulized  the  essence  of  the  argument.  All  the  rest  of  your  presenta- 
tion certainly  supports  it.  I  want  to  thank  you  very  much  for 

Lieutentant  Governor  Murphy.  Thank  you. 

The  Chairman  [continuing].  Joining  us.  We're  grateful  for  your 
participation  in  this  matter.  Thank  you. 

Our  next  witness  is  our  Attorney  General  Jim  Shannon.  He  is  a 
long-time,  personal  friend  of  mine,  who  was  very  much  involved  in 
the  Pilgrim  question  even  before  he  assumed  his  present  position. 


332 

He  is  an  uniquely  qualified  person.  Some  of  the  ramifications  of 
the  legal  relationships  between  the  State  and  Federal  government 
in  the  nuclear  power  field,  this  is  an  issue  I  know,  General,  that  we 
heard  about  earlier  in  the  course  of  our  hearing,  but  there  have 
been  a  good  deal  of  comments  from  a  number  of  witnesses  about 
how  this  relationship  could  be  adjusted  or  changed,  in  order  that 
the  principal  health  concerns  and  safety  concerns  and  the  manage- 
ment concerns  can  be  addressed  by  the  public  and  by  the  State  offi- 
cials. So  we're  enormously  interested  in  your  own  views  on  those 
subjects,  as  well  as  what  the  current  state  of  the  situation  is,  and 
what  actions  you  are  proposing  to  take  should  there  be  a  decision 
to  move  ahead.  We  look  forward  to  your  testimony,  and  we'll  ask 
you  to  be  kind  enough  to  stand. 
[Attorney  General  Shannon  sworn.] 

STATEMENT  OF  ATTORNEY  GENERAL  JAMES  SHANNON 

Mr.  Shannon.  Thank  you,  Senator  Kennedy.  I  want  to  thank 
you  for  holding  this  hearing  this  evening,  and  also  for  the  leader- 
ship that  you  have  brought  to  this  very  important  issue  to  the 
people  of  the  Commonwealth  and  in  the  U.S.  Senate. 

The  issue  before  you,  the  health  implications  of  restarting  the 
Pilgrim  nuclear  power  plant  is  one  of  tremendous  importance  to 
everybody  in  the  Commonwealth,  but  particularly  to  those  people 
who  are  neighbors  to  this  plant.  I  commend  you,  too,  for  coming 
here  tonight  so  that  the  people  who  have  been  shut  out  of  the  proc- 
ess can  finally  be  heard. 

The  facts  of  this  case  have  been  very  well  documented.  The  NRC 
currently  ranks  Pilgrim  as  one  of  the  worst  managed  plants  in  the 
country.  This  past  summer,  the  General  Accounting  Office  reported 
that  most  of  Pilgrim's  management  deficiencies  remained  uncor- 
rected. In  1982,  the  NRC  fined  Boston  Edison  $550,000  for  submit- 
ting false  information  to  the  NRC  and  improperly  operating  Pil- 
grim. 

By  1985,  the  utility  had  paid  additional  civil  penalties  totaling 
$90,000.  In  fact,  between  1983  and  1985,  the  NRC  cited  Pilgrim  for 
52  violations,  ranging  from  operations  to  surveillance  and  radiolog- 
ical control.  Finally,  in  April  1986,  Boston  Edison  shut  Pilgrim 
down. 

These  facts  compel  an  open  process,  one  in  which  Boston  Edison 
will  be  required  to  prove  to  the  public  that  its  problems  are  solved. 
Instead,  it  appears  the  NRC  intends  to  decide  the  fate  of  this  plant 
on  the  basis  of  a  closed  inspection  and  evaluation. 

The  people  of  the  Commonwealth  deserve  better  than  that.  No 
one  should  consider  reopening  the  Pilgrim  nuclear  power  plant 
until  there  has  been  a  full  adjudicatory  hearing,  which  clearly 
demonstrates  that  these  problems  have  been  solved. 

Senator  Kennedy,  both  you  and  Congressman  Studds  have  been 
forceful  in  calling  for  these  hearings.  The  NRC's  response  that  a 
public  meeting  be  held  is  completely  inadequate,  if  we  are  to  insure 
public  health  and  safety. 

In  1986,  before  my  election  as  attorney  general,  I  was  a  petition- 
er along  with  several  others  here  tonight,  calling  for  a  full  adjudi- 
catory hearing  on  the  reopening  of  this  plant.  As  Attorney  Gener- 


333 

al,  I,  along  with  Governor  Dukakis,  filed  a  second  petition  for  the 
same  full  legal  proceeding.  The  NRC  essentially  rejected  the  first, 
and  has  yet  to  act  on  the  second.  The  private  petitioners  have  ap- 
pealed the  rejection  by  the  NRC,  and  my  office  is  taking  a  lead  role 
in  that  litigation. 

I  continue  to  be  deeply  concerned,  not  only  about  the  threat  this 
plant  poses  to  public  health  and  safety,  but  the  unwillingness  of 
both  the  utility  and  the  NRC  to  address  both  these  issues  in  an 
open  hearing.  The  NRC  has  a  formal  hearing  process  and  they 
should  use  it  if  they  expect  to  restore  public  confidence  in  this  pow- 
erplant. 

These  two  petitions  are  straightforward.  They  call  for  the  NRC 
to  hold  a  hearing  in  which  Boston  Edison  must  prove  it  can  operate 
this  plant  safely  and  effectively;  a  hearing  in  which  we  can  cross 
examine  the  company's  and  the  NRC's  experts,  and  offer  our  own 
independent  experts  to  review  the  facts;  a  hearing  in  which  the 
NRC  must  issue  a  written  decision  which  is  subject  to  review  in 
courts.  The  public  deserves  a  full  hearing  on  the  safety  of  this  trou- 
bled nuclear  plants.  Boston  Edison  must  be  held  to  a  burden  of 
proof  in  an  adjudicatory  hearing  to  show  that  it  can  operate  the 
plant  safely,  something  which  it  has  yet  to  prove. 

Over  the  past  year  as  attorney  general,  I've  been  deeply  involved 
in  the  very  serious  questions  surrounding  the  regulation  of  the  nu- 
clear power  industry,  both  here  at  Pilgrim  and  through  the  licens- 
ing process  of  the  Seabrook  plant  in  New  Hampshire.  Last  year,  I 
created  a  nuclear  safety  unit  in  the  attorney  general's  office  be- 
cause it  was  clear  to  me  that  these  issues  demanded  special  re- 
sources and  technical  expertise  if  we  were  to  meet  the  industry  on 
level  ground.  I  always  expected  the  nuclear  industry  to  be  a  formi- 
dable adversary  but  what  I  did  not  expect  to  find  was  the  Nuclear 
Regulatory  Commission  intent  on  insulating  itself  from  public  par- 
ticipation and  public  process. 

In  Seabrook  we  have  seen  it  evidenced  time  and  time  again,  but 
most  recently  and  most  blatantly  in  the  Commission's  decision  to 
change  the  rules  and  attempt  to  knock  Massachusetts  out  of  the;  li- 
censing process.  And  on  that  issue  we'll  meet  the  NRC  in  court. 
Here  at  Pilgrim,  we  see  it  again  in  the  failure  of  the  NRC  to  allow 
a  full  adjudicatory  hearing  on  the  many  questions  surrounding  this 
troubled  plant.  Should  the  NRC  reject  the  Commonwealth's  pend- 
ing petition  for  enforcement  action,  then  I'm  prepared  to  take  that 
issue  to  court.  The  NRC  should  require  a  full  adjudicatory  hearing 
on  these  issues.  It  has,  after  all,  cited  the  plant  repeatedly  for  its 
mechanical  and  safety  and  management  problems. 

The  issues  that  have  brought  you  here  tonight,  the  health  impli- 
cations of  restarting  this  plant  are  both  real  and  deadly  serious. 
We  simply  cannot  allow  this  federal  agency  to  continue  its  closed 
door  deliberations  on  a  matter  of  this  magnitude.  As  Attorney  Gen- 
eral I  will  use  the  full  resources  of  my  office  to  hold  this  utility  and 
this  Commission  accountable  to  the  people  of  the  Commonwealth 
who  deserve  real  answers  obtained  in  a  formal  public  hearing  proc- 
ess. 

I  know,  Mr.  Chairman,  that  you  and  the  members  of  your  com- 
mittee will  continue  to  press  the  NRC  for  such  a  responsible  public 
response. 


334 

I  would  also  like  to  say,  Senator  Kennedy,  that  I'm  deeply  disap- 
pointed that  the  management  of  Boston  Edison  has  refused  to  par- 
ticipate in  tonight's  hearing.  They  are  in  this  room;  they  are  sitting 
in  the  audience.  If  we  are  to  trust  them,  they  should  be  at  least 
willing  to  come  forward  and  state  their  case  to  you  and  to  the 
people  of  this  area. 

[Applause] 

Mr.  Shannon.  I  think  their  management  has  been  characterized 
by  an  ostrich-like  quality  for  the  last  several  years.  They  tell  us 
things  have  changed.  I  think  their  failure  to  participate  tonight 
raises  serious  questions  as  to  whether  we  should  trust  them,  and  I 
hope  that  they  will  join  us  in  requesting  of  the  NRC  a  full  process 
where  they  can  make  their  case  in  a  way  that  might  restore  confi- 
dence in  management  and  leave  the  people  of  Massachusetts  feel- 
ing that  their  health  and  safety  will  be  adequately  protected  if  Pil- 
grim is  ever  to  go  back  on  the  line. 

[The  prepared  statement  of  Attorney  General  Shannon  follows:] 


335 


TESTIMONY  OF 
ATTORNEY  GENERAL  JAMES  SHANNON 
BEFORE  THE  SENATE  COMMITTEE  ON  LABOR  AND  HUMAN  RESOURCES 

JANUARY  7,  1988 


Thank  you,  Senator  Kennedy,  for  holding  this  hearing.   The 
issue  before  you  —  the  health  implications  of  restarting  the 
Pilgrim  Nuclear  Power  Plant  —  is  one  of  tremendous  importance 
to  everyone  in  the  Commonwealth,  but  particularly  to  those 
people  who  are  neighbors  to  this  plant.   I  commend  you,  too, 
for  coming  here  tonight  so  that  the  people  who  have  been  shut 
out  of  the  process  can  finally  be  heard. 

The  facts  of  this  case  have  been  well  documented: 


--  The  NRC  currently  ranks  Pilgrim  as  one  of  the  worst 
managed  plants  in  the  country. 

--  This  past  summer,  the  General  Accounting  Office 
reported  that  most  of  Pilgrim's  management 
deficiencies  remain  uncorrected. 

—  In  1982,  the  NRC  fined  Boston  Edison  $550,000  for 
submitting  false  information  to  the  NRC  and  improperly 
operating  Pilgrim. 

—  By  1985,  the  utility  had  paid  additional  civil 
penalties  totalling  $90,000. 

—  In  fact,  between  1983  and  1985,  the  NRC  cited 
Pilgrim  for  52  violations  ranging  from  operations,  to 
surveillance  and  raaiological  controls. 

—  Finally,  in  April  1986,  Boston  Edison  shut  Pilgrim 
down. 


These  facts  compel  an  open  process,  one  in  which  Boston 
Edison  will  be  required  to  prove  its  public  claims  that  its 


336 


problems  are  solved.   Instead,  it  appears  the  NRC  intends  to 
decide  the  fate  of  this  plant  on  the  basis  of  a  closed 
inspection  and  evaluation.   The  people  of  the  Commonwealth  of 
Massachusetts  deserve  better  than  that.   No  one  should  consider 
reopening  the  Pilgrim  Nuclear  Power  Plant  until  there  has  been 
a  full  adjudicatory  hearing  which  clearly  demonstrates  that 
these  problems  have  been  solved. 

Senator  Kennedy,  both  you  and  Congressman  Studds  have  been 
forceful  in  calling  for  these  hearings.   The  NRC's  response 
that  a  public  meeting  be  held  is  completely  inadequate  if  we 
are  to  ensure  public  health  and  safety. 

In  1986,  before  my  election  as  Attorney  General,  I  was  a 
petitioner  calling  for  a  full,  adjudicatory  hearing  on  the 
reopening  of  this  plant.   As  Attorney  General,  I  filed  a  second 
petition  for  the  same,  full  legal  proceeding.   The  NRC 
essentially  rejected  the  first  and  has  yet  to  act  on  the 
second.   The  private  petitioners  have  appealed  the  NRC  decision 
and  my  office  is  taking  a  lead  role  in  that  litigation. 

I  continue  to  be  deeply  concerned  not  only  about  the 
threats  this  plant  poses  to  public  health  and  safety,  but  the 
unwillingness  of  both  the  utility  and  the  NRC  to  address  those 
serious  issues  in  an  open  hearing.   The  NRC  has  a  formal 
hearing  process  and  they  should  use  it  if  they  expect  to 
restore  public  confidence  in  this  power  plant. 

These  two  petitions  are  straightforward  —  they  call  for 

the  NRC  to  hold  a  hearing  in  which  Boston  Edison  must  prove  it 

can  operate  this  plant  safely  and  effectively.  --  A  hearing  in 

-2- 


337 


which  we  can  cross  examine  company  and  NRC  experts  and  offer 
our  own  independent  experts  to  review  the  facts.  --  A  hearing 
in  which  the  NRC  must  issue  a  written  decision  which  is  subject 
to  review  in  the  courts. 

The  public  deserves  a  full  hearing  on  the  safety  of  this 
troubled  nuclear  plant.   Boston  Edison  must  be  held  to  a  burden 
of  proof  in  an  adjudicatory  hearing  to  show  that  it  can  operate 
the  plant  safely  something  which  it  has  yet  to  prove. 

Over  the  past  year  as  Attorney  General,  I  have  been  deeply 
involved  in  the  very  serious  questions  surrounding  the 
regulation  of  the  nuclear  power  industry  both  here  at  Pilgrim 
and  through  the  licensing  process  of  the  Seabrook  Plant  in  New 
Hampshire.   Last  year,  I  created  a  Nuclear  Safety  Unit  in  the 
Attorney  General's  office  because  it  was  clear  to  me  that  these 
issues  aemanded  special  resources  and  technical  expertise  if  we 
were  to  meet  the  industry  on  level  ground. 

I  always  expected  the  nuclear  industry  to  be  a  formidable 
adversary.   But  what  I  did  not  expect  to  find  was  a  Nuclear 
Regulatory  Commission  intent  on  insulating  itself  from  public 
participation  and  public  process.   In  Seabrook,  we've  seen  it 
evidenced  time  and  time  again,  but  most  recently  and  most 
blatantly  in  the  commission's  decision  to  change  the  rules  -- 
an  attempt  to  knock  Massachusetts  out  of  the  licensing 
process.   And  on  that  issue,  we  will  meet  the  NRC  in  court. 

Here,  at  Pilgrim,  we  see  it  again  in  the  failure  of  the  NRC 


-3- 


338 


to  allow  a  full  adjudicatory  hearing  on  the  many  questions 
surrounding  this  troubled  plant.   Should  the  NRC  reject  the 
Commonwealth's  pending  petition  for  a  hearing,  then  I  am 
prepared  to  take  that  issue  to  court. 

The  NRC  should  require  a  full  adjudicatory  hearing  on  these 
issues.   It  has,  after  all,  cited  the  plant  repeatedly  for  its 
mechanical,  safety  and  management  problems. 

The  issue  that  has  brought  you  here  tonight  --  the  health 
implications  of  restarting  this  plant  --  are  both  real  and 
deadly  serious.   We  simply  cannot  allow  this  federal  agency  to 
continue  its  closed  door  deliberations  on  a  matter  of  this 
magnitude. 

As  Attorney  General,  I  will  use  the  full  resources  of  my 
office  to  hold  this  utility  and  this  commission  accountable  to 
the  people  of  the  Commonwealth  who  deserve  real  answers 
obtained  in  a  formal  public  hearing  process.   I  know,  Mr. 
Chairman,  that  you  and  the  members  of  your  committee  will 
continue  to  press  the  NRC  for  such  a  responsible,  public 
response. 

Thank  you. 


-4- 


339 

The  Chairman.  Thank  you  very  much,  Attorney  General  Shan- 
non. Let  me  ask  you  a  few  questions.  Maybe  you  can  review  with 
us  for  just  a  few  minutes,  what  the  legal  situation  is  relevant  to 
the  State  of  Massachusetts  and  the  NRC,  should  the  NRC  plan  to 
give  approval  for  the  start-up  of  Pilgrim  I.  What  powers  reside  in 
you  and  the  state  to  affect  that  decision?  Maybe  you  could  discuss 
that  for  us  if  you  will. 

Mr.  Shannon.  I'll  be  happy  to.  As  has  been  pointed  out  by  previ- 
ous witnesses,  there  are  really  two  petitions  which  have  been  filed, 
one  which  has  been  essentially  rejected  by  the  NRC.  The  Common- 
wealth is  now  involved  as  intervenor  on  appeal  of  that  decision. 
The  other  one  is 

The  Chairman.  What  is  that? 

Mr.  Shannon.  That  is  the  petition  which  was  put  together  by 
MASSPIRG  included  a  number  of  members  of  the  State  legislature, 
myself,  and  Lieutenant  Governor  Murphy,  and  was  filed  during  the 
summer  of  1986. 

In  the  fall  of  1987,  I  filed  on  behalf  of  Governor  Dukakis  and 
myself  another  petition,  based  on  some  of  the  old  concerns  that  we 
had  and  some  new  ones  which  had  been  raised  about  this  particu- 
lar reactor  and  which  had  come  to  light  after  the  Barry  report  on 
evacuation  planning.  We're  waiting  for  a  decision  from  the  Nuclear 
Regulatory  Commission  on  that  petition. 

If  the  NRC  denies  us  a  hearing  after  that  process,  then  we'll  take 
that  matter  to  the  Federal  court,  it  is  our  right.  There  has  been 
some  suggestion  that  the  Federal  regulation  completely  preempts 
state  officials  from  acting  to  protect  the  health  and  safety  of  the 
public;  well,  we  don't  accept  that  for  a  moment.  I  think  that  Gover- 
nor Dukakis,  myself,  other  responsible  state  officials  have  implicit 
authority  to  act  to  protect  the  people  of  Massachusetts  and  we're 
willing  to  act  to  protect  the  people  of  Massachusetts,  and  we're 
willing  to  assert  those  arguments  in  court  as  well  around  the  Pil- 
grim plant  as  we  are  around  the  Seabrook  nuclear  plants. 

The  Chairman.  You  wouldn't  draft  the  law  the  way  it  is  now? 

Mr.  Shannon.  That's  right,  Senator.  I  think  I  would  be  a  little 
clearer  about  where  the  Federal  Government's  authority  ends  and 
the  States'  begins.  What  is  clear  though,  and  I  was  in  the  Congress 
when  that  legislation  was  being  debated,  as  were  you,  and  what  is 
clear  is  that  in  and  post-Three  Mile  Island  era.  Congress  intended 
for  the  States  to  play  a  very  important  role  along  with  the  Federal 
Government  to  actively  protect  their  own  citizens. 

As  a  matter  of  fact,  the  premise  of  all  congressional  action  was 
that  people  could  not  be  protected  unless  the  states  were  included 
in  that  process.  So  I  don't  yield  for  a  moment  to  the  notion  that  we, 
the  state  officials,  do  not  have  the  authority  to  act  to  protect  people 
from  the  dangers  of  a  poorly  managed  or  poorly  constructed  power 
plant. 

The  Chairman.  I  think  that  you  should  know  that  some  of  the 
NRC  people  are  very  adamant;  they  say  that  they'll  be  darned  if 
they  will  let  these  nuclear  powerplants  be  held  hostage  to  the 
whims  of  the  states.  How  do  you  react  to  that? 

Mr.  Shannon.  I've  heard  that  suggestion  from  some  people  in 
the  NRC.  The  notion  that  that  we  are  acting  arbitrarily  and  capri- 
ciously, particularly  in  this  case,  is  just  outrageous. 


340 

This  is  documented  to  be,  by  the  NRC,  one  of  the  most  poorly 
managed  nuclear  powerplants  we  have  ever  seen  in  the  history  of 
nuclear  power.  As  late  as  just  a  few  months  ago,  further  deficien- 
cies were  pointed  out  in  the  way  in  which  the  Pilgrim  nuclear 
power  plant  has  been  run,  by  the  Nuclear  Regulatory  Commission. 
They  have  fined  Boston  Edison  in  the  past,  and  yet  these  deficien- 
cies have  not  been  corrected.  Serious  questions  have  been  raised 
about  this  reactor  over  the  period  of  the  last  year,  so  the  notion 
that  we  are  acting  at  all  arbitrarily  or  that  this  plant  is  being  held 
hostage,  is,  I  think,  an  affront,  and  I  don't  think  that  the  people  of 
the  Commonwealth  are  going  to  buy  that  and  I  don't  think  people 
around  the  country  will  either. 

The  Chairman.  You  are  familiar  with  the  MASSPIRG  report  on 
the  economic  implications  of  a  permanent  shutdown  of  Pilgrim? 

Mr.  Shannon.  I  am. 

The  Chairman.  Then  you  know  that  they  conclude  that  the  utili- 
ty customers  would  actually  save  money  if  that  happens;  is  that 
right? 

Mr.  Shannon.  That's  right. 

The  Chairman.  Have  any  of  your  people  in  the  attorney  gener- 
al's office  looked  at  that  question? 

Mr.  Shannon.  Yes,  Senator,  we  have  looked  at  the  MASSPIRG 
report.  We  do  find  it  of  real  value  as  part  of  our  evaluation.  We  are 
looking  at  the  question  of  economics  at  Pilgrim  right  now.  While  I 
can't  give  you  a  definitive  answer,  I  can  say  this.  On  the  basis  of 
the  study  we  have  done  to  date,  we  have  concluded  that  at  best. 
Pilgrim  is  now  marginally  economic.  I  think  of  the  safety  concerns 
apart  from  the  economics  because  I  don't  think  that  there  is  any 
price  we  can  put  on  the  health  and  safety  of  the  people  who  live  in 
the  areas  around  nuclear  power  plants. 

[Applause.] 

Mr.  Shannon.  But  apart  from  the  safety  concerns  that  I've  got, 
we  must  look  at  those  economic  questions  and  I  think  that  when 
we  look  at  them,  we  are  going  to  find  a  lot  of  what  MASSPIRG  has 
said  proves  to  be  absolutely  correct. 

The  Chairman.  Is  it  safe  for  me  to  assume  that  if  a  decision  is  to 
move  ahead,  that  you  are  going  to  exercise  all  the  rights  as  attor- 
ney general  in  every  possible  way  to  do  everything  that  you  possi- 
bly can  to  insure  that  that  eventuality  does  not  come  about? 

Mr.  Shannon.  Senator,  as  you  know  and  the  people  of  the  Com- 
monwealth know,  we  have  been  very  actively  involved  over  the  last 
year  in  asserting,  at  every  point  we  can,  the  rights  of  the  people  of 
the  Commonwealth  in  protecting  them  against  the  Seabrook  power 
plant.  I  want  to  say  here  tonight  that  I  feel  equally  about  the  Pil- 
grim nuclear  power  plant.  The  Pilgrim  nuclear  power  plant  has 
the  added  disadvantage  of  a  proven  record  of  mismanagement  on 
the  part  of  the  utility  company  which  manages  them,  and  I  intend 
to  fight  just  as  hard  to  protect  people  around  Pilgrim  as  we  have 
around  Seabrook. 

[Applause.] 

Mr.  Shannon.  Senator,  I  would  like  to  ask  that  the  petition  filed 
by  Governor  Dukakis  and  myself  be  included  in  the  record. 

[The  petition  referred  to  follows:] 


341 


UNITED  STATES  OF  AMERICA 
BEFORE  THE  NUCLEAR  REGULATORY  COMMISSION 

PETITION  OF  MICHAEL  S.  DUKAKIS,  GOVERNOR  AND 
JAMES  M.  SHANNON,  ATTORNEY  GENERAL  FOR  THE 
INSTITUTION  OF  A  PROCEEDING  PURSUANT  TO 
10  C.F.R  S2.202  TO  MODIFY,  SUSPEND,  OR 
REVOKE  THE  OPERATING  LICENSE  HELD  BY 
THE  BOSTON  EDISON  COMPANY  FOR  THE 
PILGRIM  NUCLEAR  STATION 


Dated:   October  15,  1987 


342 


'i.  ^; 


:-::^:j::::;-i 

zr.D-zMi   :.-   3£.-^::'J5  AA:i\zz?.:\i  o- f  :::e-]c:;s 3 

iv.        j/£R/:iV 3 

3.     3e::d'3  pas:  pe?,- dr:ianc£ 4 

iEZ^'s    3A1?    Evaluaf.ons 5 

3£:o'3    '.eg^laiDcy   Viola':  i  op.s 

;.  I'.zzz-.'.z   ;:;^:::a  o?  3ECo's  ?E::^FOR'iA"iCE  level  ....  9 

SEZd's  193"  3A1?  Report "- "' 

Rec3-:i  Reoorto  of  Violations 2 

-/:je:ice  iha:  indizates  thai  .a  plast  specific 

=  RA  fZll-O.VED  3^:  I'IPLEMENTATION  OF  AMY  INDICATED 
SAFilr  AZDlZ:Z\-:y.iS    SHOJLD  3£  REQUIRED  PRIDR 

:z   p:'-3r:'V3  restart •  •  1-2 

r  _•  -  J  -■  —  r     -  r     "   ;  i.  J  £  -J  \  TE    E'^ERGENCY    PREPAREDNESS       ...        15 


343 


aSFORS    THE    'i'JCLz.\R    RE^'JLATDRY     3  0«''!  I  33  :  3>l 

PETinON    DF    MICH'VEL    S.     DUKAKIS,     lOVER-jQR    i,-;D 

JAMES  '1.  3HANM0M,  ATTORNEY  GENERAL  -OR  "-{-. 

INSTITUTION  OF  A  PROCEEDING  PURSUANT  TO 

10  C.r.R  §2.202  TO  MODIFY,  SUSPEND,  OR 

REVOKE  THE  OPERATING  LICENSE  HELD  3Y 

THE  BOSTON  EDISON  COMPANY  FOR  THE 

PILGRIM  NUCLEAR  STATION 


I.  INTRODUCTION 


Governor  Michael  3.  Dukakis  and  Attorney  General 
JaTies  M.  Shannon,  pursuant  to  10  C.F.R.  §2.206,  hereby  request 
that  the  Director  of  the  Office  of  Nuclear  Reactor  Regulation 
institute  a  proceeding  pursuant  to  10  C.F.R.  §2.202  to  -nodify, 
suspend,  or  revoke  the  operating  license   ^Id  oy  3oston  "dison 
Co.-ipany  ("3EC-."  or  "the  Co-ipany"  )  for  t-e  Pilgrim  Nuclear 
Po^er  Station  '"PilgriTi")  in  Plynouth,  Ma -sachuset  t  s  .   This 
petition  is  filed  on  behalf  of  the  ConTionwea  It  h  of 
Massachusetts  and  its  citizens.   The  Governor  and  the  Attorney 
General  oase  this  request  on  evidence  of  continuing  serious 
nanagerial  deficiencies  at  the  plant,  on  evidence  that  a  clant 
specific  prooabi  list  ic  risk  assessment  ("PRA")  as  well  as  :-.e 
implementation  of  any  safety  modifications  indicated  thereby 
should  be  required  prior  to  Pilgrim's  restart,  and  on  evidence 
that  the  state  of  emergency  oreparedness  does  not  orovide 
reasonaole  assurance  that  adequate  protective  measure;  can  and 


344 


will  be  taken  in  the  event  of  a  raaiDloqical  energenc/  i^ri-.^ 
operations  at  the  Pilirm  olant.   The  Governor  and  f'-e  Xttor-.ev 
General  submit  that  this  evidence,  as  set  forth  oelow, 
demonstrates  the  necessity  of  Nuclear  Regulatory  Com-iission 
("NRC")  action  pursuant  to  10  C.F.R.  §2.202. 

Further,  the  Governor  and  the  attorney  General  oelieve  that 
the  puDlic  interest  requires  that  the  SRC  exercise  its 
authority  under  10  C.F.R.  §2.202(f)-^  so  that  SECo.  is 
prevented  from  proceeding  any  further  -^ith  the  restart  of 
Pilgrim—   until  a  formal  adjudicatory  hearing  has  been  held 
and  findings  of  fact  are  made  concerning  the  safety  questions 
surrounding  the  continued  operation  of  the  Pilgrim  plant.   In 
particular,  the  Governor  and  the  attorney  General  request  that 
the  'ARC    issue  an  order,  effective  immedi  =  -ely,  modifying  3SCo's 
operating  license  to  preclude  3ECo.  from  -aking  any  steos  m 


1/      10  C.E.R.   2.02(f)  provides: 

•Vhen  the  Executive  Director  for  Operations/ 
during  an  emergency  as  determined  ":>'/    the  "00,  or 
the  Director  of  "luclear  Reactor  Regulation, 
Director  of  Nuclear  Material  Safety  and 
Safeguards,  Office  of  Inspections  and 
Enforcement,  as  appropriate,  finds  that  the 
public  health,  safety,  or  interest  so  requires 
or  that  the  violation  is  willful,  the  order  to 
show  cause  may  provide,  for  stated  reasons,  tr.at 
the  proposed  action  be  temporarily  effective 
pending  further  review. 

2/      At  each  step  of  BECo's  so-called  "power  ascension" 
program  there  is  an  increase  in  the  probability  of  an 
accident  at  Pilgrim  as  well  as  in  the  ootential 
consequences  of  such  an  accident.   See  Affidavit  of 
Steven  C.  Sholly  (attached  hereto  as  Attachment  1). 


-  2  - 


345 


Its  power  ascer.  3.3r.  pr^gra^n  ^nt^l  the  hearing  is  nald  and  i-^.  e 
findinqs  are  made. 

Recent  events  at  Pilgri.'n  indicate  that  3'=:Co.  has  not 
corrected  the  lonq-standmg  ^anaqerial  shortcomings  that  have 
olagued  the  plant.   In  the  areas  of  security,  radiological 
controls,  personnel  management,  and  corporate  culture,  the 
-nanagement  of  Pilgri-n  continues  to  be  seriously  flawed.   ^s  a 
result,  Pilgrim  poses  an  unreasonable  risk  to  puolic  health  and 
safety.   Its  continued  operation  under  the  present    ; 
circumstances  is  ni7\ical  to  puolic  health  and  safety. 

^.       0VERVI3W 


PilgriTi  commenced  co.7.mercial  operatio-  in  June,  1972,  when 
3ECo.  received  an  operating  license  for  t-e  plant.   During  the 
intervening  fifteen  year  period  of  operation  by  3SCo.,  Pilgrim 
has  nad  a  capacity  factor  of  approximately  50  percent, - 
which  compares  quite  unfavorably  with  the  average  for  all  "ew 


England  nuclear  plants  of  approximately  67  percent. - 


4/ 


2/      The  "caoacity  factor"  for  a  plant  is  a  measure  of 
oerformance" in  terms  of  the  power  it  has  actually  delivered 
over  a  period  of  time  relative  to  the  power  it  was  caoaole  of 
delivering  over  that  same  period  of  time.   It  is  calculated  by 
dividing  the  actual  number  of  kilowatt  hours  oroduced  oy  the 
plant  m  the  period  of  measurement  by  the  product  of  the 
plant's  rated" kilowatt  capacity  and  the  numoer  of  hours  m  the 
period. 

4/   Electric  Council  of  New  England,  New  England  Nuclear  News, 
fjune,  1937)  (Attached  hereto  as  Attachment  2) . 


346 


3.     3E.:-'3    PAST    ?ERrO?>V'-: 


ilanc    has    09en    oat    of    service 


\pz.'.,     19S6,  w- 


the  NRC,  m  Conf  1  nat  ory  Actior.  letter  36-10,  oraered  a 
shutdown  after  rec_imng  operational  proble-^s  at  the  pla-.t.- 
?ilqri.T>  has  been  beset  with  managerial  probleiis  from  tne 
outset.   3ECo.  has  consistently  received  low  ratings  m  the 
VJac's  Systematic  Assessment  of  Licensee  Performance  ("SAL?") 
reoorts.   Pilgrim  has  been  identified  by  the  'JRC  as  one  of  t-.e 
worst  run  and  least  safe  plants  m  the  country-   and  3ECo. 
was  ordered  to  initiate  performance/management  improvement 
programs  in  1982  and  1984.-   3ECo.  has  been  the  subject  of  a 
long  line  of  enforcement  actions  as  a  result  of  regulatory 
violations.   While  the  NRC's  efforts  to  spur  3ECo.  to  a  higher 
level  of  oerformance  have,  on  occasion,  met  with  some  initial 
success,  a  review  of  3ECo's  performance  -^cord,  however,  shows 
that  all  such  successes  have  been  short  l.ved.   Indeed,  3ECo. 


5/   Confirmatory  \ction  Letter  36-10  was  clarified  and  expanded 
Tn  an  suosequent  letter,  dated  August  27,  1937,  from  the  MRC 
Region  1,  Regional  Administrator  to  3ECo's  Chief  Operating 
Officer.   (attached  hereto  as  Attachment  3).   In  this  letter, 
3SCo.  was  informed  that: 

In  light  of  the  number  and  scope  of  the 
outstanding  issues,  I  (the  Regional 
Administrator)  am  not  prepared  to  aporove 
restart  of  the  Pilgrim  facility  until  you 
(BECo.)  provide  a  written  report  that  documents 
3ECo's  formal  assessment  of  the  readiness  for 
restart  operation. 

5/   3oston  Olobe,  May  23,  1986. 

7/   Order  'lodifymg  License  Effective  Immediately,  47 
Fed.  Reg.  4171  (January  23,  1987). 


347 


appears    co    r.ave    an    organic    inaoility    to    -nanage    Pilgm 


a  n 


effective  and  safe  iianner.- 


3/ 


*  *   aRPn  ' 


3ECo's  S\LP  Evaluations 


3ECo.  has  consistently  received  low  ratings  m  SAL? 


9/ 
report  s .- 


8/  Altho'jqh  It  IS  the  f 
Pilgrim  plant  which  are 
significant  that  finding 
confirm  3ECo's  manageria 
extend  to  the  other  aspe 
Edison  Company,  "^assachu 
Docket  No.  87-lA-A  (1987 
generating  unit).  Of  pa 
3ECo.  responds  to  the  id 
half-hearted  (although  s 
solutions  that  treat  the 
series  of  decisions  by  t 
Utilities  that  address  3 
sources  of  power  in  the 
the  construction  of  the 
Company,  MDPU  905  (1982) 
to  meet  its  future  power 
■.'Jo.  36-270  (found  reason 
and/or  skill  to  fulfill 


ailings  of  3ECo's 
the  subject  of  th 
s  have  been  "nade 
1  deficiencies  an 
ct  s  of  Its  busine 
setts  Department 
)  ( imprudence  in 
rticuiar  relevanc 
entification  of  d 
ometimes  quite  sh 

symptoms,  not  th 
he  f^assachuset t s 
ECo's  need  to  co-. 
aftermath  of  the 
Pilgrim  II  nuclea 

(ordering  BECo. 

needs);  Soston  " 

to  believe  3ECo 
public  service  ob 


management  of  the 
is  pet  It  ion,  it  is 
in  other  settings  tha 
d  indicate  that  thev 
ss .   See   e.g. ,  3os 


on 


of  Public  Utilities 
operation  of  oil  fired 
e  to  the  notion  that 
eficiencies  with 
owy) ,  short-term 
e  disease,  is  the 
Department  of  Public 
■■-der  and  develop  new 
.991  cancellation  of 


3oston 


son 


'  unit 

-.  0   develop  a  new  "plan 

iison  Company,  MDPU 


lacked  commitment 
ligat ion) 


9/      The  3ALP  process  is  the  mechanism  by  which  the  NRC  on  a 
periodic  oasis  -systematically  assesses  the  overall  oerformance 
of  a  licensee.   For  each  assessment  period  (generally  12  to  13 
months)  a  3oard  of  NRC  officials  evaluates,  in  accordance  with 
preestaolished  attributes  and  rating  guidance,  the  licensee's 
performance  for  each  of  the  various,  preest ablished  functional 
areas  and  rates  the  licensee's  performance  m  each  area.   The 
3oard  also  compares  the  licensee's  performance  for  the  current 
period  with  that  of  the  previous  assessment  period  and 
identifies,  for  further  followup  and  inspection,  any  areas 
where  the  licensee's  corrective  action  to  improve  oerformance 
has  not  been  fully  effective. 


Arizona  Public  Service  Company,  (Palo  Verde  Nuclear  Generating 
Station,  Unit  2),  DD-86-8,  24  NRC  151,  156  (1986). 


348 


:n    135';,    3£Co.     received    ratings    mdicacing    sig* 


1 :  .ca- 1  >je-.<'.iB3 


in  three  of  the  nine  fanctional  areas  evaljated.   The  -lost 
recent  SAL?  Report,  seven  years  later,  indicates  that 
conditions  have  not  iTiproved  but  rather  have  vor~'ned.   3EC~. 
received  ratings  indicating  significant  weaknesses  m  five  of 
the  twelve  fanctional  areas  evaluated.   It  has  only  once 
received  a  SALP  Report  without  a  rating  indicating  a 
significant  weakness.   On  all  other  occasions,  it  has  received 
reports  indicating  significant  weaknesses  in  at  least  two 
functional  areas.   (See  Appendix  I:   3ECo.  SALP  History 
Tabulat ion ) 

Of  particular  significance,  every  time  Quality  Assurance 
has  been  assessed  as  a  separate  functional  area  during  a  SALP 
review,  3ECo.  has  received  the  lowest  po.--ible  rating.   These 
findings  are  indicative  of  the  inef f ect i /^ness  of  3SCo's 
-nanaqeTient  .   They  are  a  neasure  of  its  i-.aoility  and/or  its 
lack  of  coTTiitTient  to  run  the  plant  m  a  effective  and  safe 
■nanner. 

Although  3EC0.  has  at  one  tiie  or  anotner  received  the 
lowest  possible  rating  in  all  but  three  of  the  twelve 
functional  areas  covered  by  the  :)RC's  SAL?  process,  these 
individual  poor  SAL?  ratings  are  not  the  nost  troubling  asoect 
of  3ECo's  SALP  record.   Instead,  the  -nost  trouoling  and  telling 
facet  of  3ECo's  SAL?  record  is  the  Conpany's  distinct  inability 
to  naintam  any  per iod-to-?eriod  performance  improvements. 
3ECo.  has  at  one  time  or  another  improved  its  SALP  oerformance 


-  6 


349 


in  eignt  fjnctionai  areas.   However,  ic  has  not  oeen  ao'.e  to 
sustain  the  increased  level  of  performance  m  seven  of  t-ose 
eight  areas.   In  all  but  one  instance,  3ECo's  I'^proved 
perforTiance  proved  to  be  short-lived  and  its  oerf oriiance 
subsequently  fell  back  to  lower  levels.   This  is  not  surprising 
as  an  ever  recurring  the-ne  in  MRC  evaluations  of  3ECo'3 

perfor'^ance  is  that  NRC  oversight  and  prompting  is  necessary  at 

1  0/ 
every  stage  of  Pilgrim's  operation. —   The  increased  NRC 

attention  (i.e.,  oversight  and  prompting)  that  a  "3"  rating 

calls  for  has,  on  occasion,  produced  better  performance  bv 

3ECo.   However,  when  that  level  of  attention  returns  to  that 

norm,  3ECo's  performance  falls  below  the  norm.   BECo's  3ALP 

track  record  is  oroof  of  the  proposition  that  BECo.  by  itself 

has  not  effectively  operated  Pilgrim  and  ' nat  the  short-term 

solutions  It  has  adopted  m  response  to  :riticism  have 

mvariaoly  permitted  the  reoccurrence  of  ---.e  original  oroolems. 

**  3ECo's  Regulatory  Violations  ** 

BSCo.,  an  enforcement  action  record  that  is  a  mirror  of  its 
3\L?  Report  record.  It  has  had  at  least  one  Severity  Level  III 
violation  during  each  of  the  past  six  years. -=—   ( See 


10/ 


,  g.,  1987  S.MP  Review  at  3;  1936  SAL?  Review  at  7, 


11/   \s  set  forth  in  10  C.-.R.  Part  2,  Aipoendix  C ;   General 
Statementof  Policy  and  Procedure  for  NRC  Enforcement  Actions, 
regulatory  violations  are  categorized  into  five  descending 
levels  of  severity.   Level  III  corresponds  with  "violations 
tnat  are  cause  for  significant  concern." 


-  7  - 


350 


\ODi:-.i:-< 


H2d.     viol  at:  3'J3  TAa'Jl.M'ION'S  -  SEVERITY  LIV~1 


VIOLATIDNS )   In  Che  area  d?  Sec^niy  aTd  Safe^jar^s,  3"Co.  -.ai 
a  Severity  Level  III  violation  m  all  but  one  of  fne  years 
oetween  1931  and  1936.   In  1932,  a  civil  oenalty  m  tne  a-nount 
of  $550,000  --  at  the  tme  the  largest  oenalty  to  have  ever 
oeen  assessed  by  the  NRC  --  was  levied  against  ?ECo.  for 
serious  plant  operations  violations  and  for  sabmitting  false 
information  to  the  NRC. — While  the  number  of  such  Severity 
Level  III  violations  discovered  at  Pilgrim  has  not  exceeded  two 
m  any  single  year  since  1981,  the  number  of  Severity  Level  IV 
violations  per  year  has  more  than  doubled  in  the  past  few  years. 

BSCo's  enforcement  action  record  also  mirrors  its  SALP 
Report  record  m  demonstrating  3ECo's  chronic  recidivism.   It 
nas  been  cited  five  times  for   Radiologic  =•.  1  Controls  violations 
involving  vaste  shipment  packaging  requirements. — 

It  has  oeen  cited  five  times  for  Security  and  Safeguards 
violations  involving  the  control  of  sensitive  material  such  as 
<eys  to  vital  areas,  security  plans,  and  firearms. — 


1_2/   U.S.  General  Accounting  Office,  Reoort  to  the  Honorable 
Mfonse  M.  D'Amato,  U.S.  Senate:   Maclear  Regulation  Efforts  to 
Ensure  N'uc^ear  Power  Plant  Safety  Can  3e  Strengthened 
(3AD-RCED-a7-141  August,  1987),  pp.  36-3''. 

13/   See  NRC  Enforcement  Summary  Tables  taken  from  various  SAL? 
Reports  (attached  nereto  as  Attachment  4). 

14/   Id. 


351 


c.      ?;£C;.-.:    ::;j:::a  Or    becd's   =>:.-':  j-^-'-/. ,z.   ie/^i 


'he  Tiost  recent  indicia  o- 


level  of  3lCd'3  oerfor-'a-.: 


m  Tianaging  Pilgrm  are  consisten':  with  its  past  oerf  or'^anc? . 
They  confirti  the  nocion  that  9ECo.  appears  to  oe  orianically 
incapable  of  Tianaging  a  nuclear  facility.   Notwithstanding  the 
frequent  incantation  by  senior  TianageTieht  of  a  progra-n  for  t -.e 
"pursuit  of  excellence,"  the  addition  of  new  personnel  and  the 
expenditure  of  larg-?  sums  of  Tioney, —   the  available  evidence 
indicates  that  3ECo.  has  not  changed.  Its  1987  SALP  Report 
shows  that  the  Company  continues  to  merit  the  lowest  possible 
ratings  in  many  functional  areas.   3ECo.  continues  to  be 
incapable  of  maintaining  performance  gains.   On  the  basis  of 
news  reoorts,  it  appears  that  3ECo's  management  of  the  Security 
and  Safeguards  function  is  deteriorating,  -ot  improving, 
"urther,  -n  the  basis  of  statements  made  ■/  NRC  officials  at  a 
recent  meeting,  the  :IRC  has  received  and  .s  investigating 
allegations  that  the  company  may  be  compromising  safety  oy 
overworking  its  or  its  contractors'  employees  m  an  effort  to 
return  the  olant  to  service  soon.   This  evidence  sumests  that 
3ECo'3  claim  to  oe  approaching  readiness  for  restart  may 


15/   E.q, 


NRC  Docket  ••10.  50-293,  Offic 


Office  of  Nuclear  Reactor  Regulation, 
Edison  Re:  Pilgrim  Status  and  ^ctivi 
Readiness,"  pp.  13-14,  13-20  (Septemb 
"9/24/37  MRC/3EC0.  Readiness  Meeting" 
Steohen  J.  Sweeney,  President  and  Chi 
3oston  Edison  Company,  to  the  'J .  S .  4o 
Suocommittee  on  Energy  Conversation  a 
on  Energy  and  Commerce  July  16,  1986, 
as  "Attachment  5" ) . 


iciai 
":iee 
ties 
er  24 
).  .(T 
ef  Ex 
use  0 
nd  Po 


.  ra 

t  mg 
Lead 
,'l9 
est  1 
ecut 
f  Re 
wer 
4-5 


n  s  c  r  1  p 
W 1 1  n 
mg  to 
3^)  (  h 
mony  S 
ive  Of 
o  resen 
of  the 
( att ac 


t  ot 
3osto 
Rest 
e  *'  e  1  n 

uomi  t 


art 
after 
*■  ed  bv 


i  «  3  ^  , 


t  a  1 1 V 

Comm 

h  "*  d  h 


es. 

It  t  ee 
ereto 


9  - 


352 


16/ 


oe  riast  .■  and  -nisleading. — 


**  3ECo'3  193''  3MP  Repo: 


On  ^oril  3,  1987,  the  NRC  released  a  S^LP  Report  for  3ECo. 
wnich  was  based  on  the  results  of  various  inspections  and 
evaluations  conducted  at  Pilgrim  over  the  period  from 
Novemoer  1,  1935  through  January  31,  1987.   Ratings  were  given 
for  3ECo's  performance  in  twelve  functional  areas.   In  keeping 
with  Its  past  record,  3ECo.  received  the  lowest  possible 

17/ 

ratings  in  five  of  the  twelve  functional  areas. —   it 
received  the  highest  possible  rating  in  only  two  functional 
areas.— ^   The  picture  painted  in  the  SALP  report  is  one  of  a 
plant  witn  "(p)oor  management  control,"  an  "obscured  ...  chain 
of  command  and  wea<ened  accountability,"  ;nd  " ( s ) signif icant 


recurring  program  weakness 


in  some  fu-.ctional  areas, 
,.11/ 


showing  the  effect  of  ...  long-term  probleis.  — 


16/   3ECo's  claim  of  readiness  should  be  measured  against  its 
Idootion  of  9/24/37  SRC/BECo.  Readiness  Meeting,  o.  43.   This 
tendency  to  ignore  reality  m  the  operation  of  the  nlant  nas 
been  or«vously  found  to  be  undesiraole.   See  3oston  Edison 
Tomoany,  MDP'J  NO.  1009-F  (1982)  (3ECo.  denied  where  evidence 
estaolished  that  it  had  imprudently  underestimated  the 
necessary  time  required  to  perform  outage  tasks). 

17/   The  five  areas  were:   Radiological  Controls,  Surveillance, 
Fire  Protection,  Security  and  Safeguards,  and  Assurance  of 

Quality. 

13/   The  two  areas  were:   Outage  Management,  "Modifications,  and 
Technical  Support  Activities  and  Engineering  and  Corporate 
Tecnnical  Suoport. 

19/   1987  SAL?  REPORT  at  3. 


10  - 


353 


Df  part.cjlar  i-iportance  to  this  Petit. 01,  were  SM? 
ratings  in  three  areas  where  =5ECo.  hai  previo^slv  i-norovei  .ts 
perf  orTiance.   in  the  fjnctional  areas  of  Sa  rvei  I  lance ,  ?ire 
Protection,  and  Licensing  Activities,  3ECo.  had  m  the  oast 
iTiproved  its  ratings  between  periods  --  m  fire  orotection,  it 
had  gone  from  a  "3"  to  a  "1"  oetween  its  third  and  fourth  SA'^P 
Reports  —  but  by  the  tine  of  the  review  for  the  1937  ShL? 
Report,  Its  perf oriiance  had  fallen  back  to  earlier  levels. 

With  respect  to  the  functional  area  of  Security  and 
Safeguards,  the  1937  SALP  Report  discussed  continuing  hardware 
proolems,  BECo's  excessive  reliance  upon  contractors,  and 

TianageTient  '  s  failure  to  give  this  area  sufficient 

20/ 
attention. —   The  report  noted  that  BECo's  corrective 

actions  for  deficiencies  in  this  area  hai  not  generally  been 

effective  and  referenced  three  degradat  lo-.s  m  vital  area 

barriers  that  had  occurred  during  the  ev=.-jation  neriod.— ^ 


20/   Id.  at  31-34. 


21/   The  CoTi-ii  ssion' s  regulations  define  a  "vital  area"  as  any 
area  wnich  contains: 


any  equipnent 
failure,  dest 
directly  or  1 
and  safety  by 


'Stem,  device 

ion,  or  rele 

rectly  endang 


»  sy 
ruct 
ndi  r 
exoosure  to  radiation 


•material,  the 
f  w  h 1 c  n  could 


f  or 
ase  0 

er  the  ouolic  health 


or 


systems  which 
protect  publi 
failure,  desc 
considered  vi 
( 1 )  ( emphasis 
located  withi 
to  vital  equi 
least  two  ohy 
§73.50(b) ( i) . 
be  controlled 
author i2at ion 

to  which  barr 
"channel  pers 
§73.45(0) (  1) ( 


would  be  required  to 
c  health  and  safety  f 
ruction,  or  release  a 
tal  areas.   10  C . F . R. 

added ) .   Such  areas 
n  a  protected  area  su 
pment  requires  passag 
sical  barriers."   10 
Access  into  a  prote 

through  the  checking 

and  identity  at  entr 
lers  surrounding  the 
ons  and  material."   1 
1)  and  73.50(c)  . 

-  11  - 


qui  p-ient 

function  to 
ollowng  such 
re  also 

§■73. 2(h)  and 
are  to  "be 
ch  that  access 
e  through  at 
C- .R. 
cted  area  is  to 

of 
y  cont  rol  ooint  s 

protected  area 
b  C.F.R 


354 


**   .Recent  :^e ports  of  Vi^litnr. s  ** 

On  the  basis  of  news  reports  and  statements  -lade  oy  ".^Z 
officials  at  a  recent  -neetinq,  it  appears  that  3ECo.  has 
suffered  fron  at  least  four  significant  Security  and  Safe^uarrs 
lapses  m  the  past  six  months:   a  Tiisplaced  lun;  a  misplaced 
set  of  sensitive  -ceys;  a  "serious  degradation  in  a  vital  area 
barrier;"  and  ineffective  identification  cards. —   While  all 
four  alleged  lapses  would  be  significant,  t.ne  latter  three 
would  be  a  particularly  strong  indication  of  BECo's  failure  to 
learn  from  its  past  mistai^es  --  nearly  identical  lapses  have 
occurred  in  the  past. — 

Further,  allegations  have  recently  been  made  which  ^i^C 
stated  at  a  recent  meeting  that  they  are  investigating  that 

3ECo.  may  oe  compromising  worker  and/or  c.ant  safety  by 

24/ 
requiring  excessive  overtime. — 

III.   EVIDENCE  VHW    INDICATES  THAT  A  PLANT  SPECIFIC 

??^A  FOLLOWED  3Y  IMPLS-^ENT ATION  OF  ANY  INDICATED 
SAFETY  MODIFICATIONS  SHOULD  3E  REQUIRED  I^O 
PILGRIM'S  RESTART. 

Pilgrim  is  a  GE  Mark  I  design  olant .   As  such,  it  has  a 
primary  containment  which,  by  nearly  unanimous  agreement,  has 
an  extremely  high  probability  of  failure  m  the  event  of 


22/   Boston  Glooe,  Seotemoer  4,  1987,  p.  1;  3oston  Glooe, 
September  9,  1937,  o.  21;  3oston  Herald,  September  10,  i93  , 
p.'  24. 

23/   See  1985  SALP  Reoort,  o.  40;  1933  SAIP  Reoort  ,  op.  41-43, 
T982  SAL?  Report,  p.  38  (included  in  Attachment  3  hereto). 

I±/      Boston  Globe,  September  29,  1987,  p.  21. 


12  - 


355 


certa.T  a?r.3e-.  ts.  — ''         This  charac.erLStic  is  esper.allv 
critical  since  Mark  I  design  reactors,  such  as  ?ilgri-n,  do  not 
have  the  backup  of  a  secondary  contam-ient  structure  which  can 
withstand  any  significant  position  pressure.  (  "P'/^s" )  .2-i'^   i-, 
fact,  Pilgrm's  so-called  "containment  building"  is  not  reallv 
designed  to  perform  a  backup  function.   It  has  "blow  panels" 
which  m  some  design  and  most  severe  accidents  would  activate 
and  create  a  ready  path  for  hazardous  radioactive  materials  to 
escape  into  the  environment. —   The  combination  of  an 
extremely  vulnerable  primary  containment  structure,  a  secondary 

containment  not  designed  to  provide  an  effective  backup,  and 

2  3/ 
the  large  population  in  the  immediate  vicinity  of  Pilgrim — 

compel  the  Governor  and  the  Attorney  General  to  request  that 

the  SRC  modify  the  Pilgrim  operating  lice-^e  to  bar  restart 

until  a  plant  specific  probabilistic  ris'  assessment  ("PRA")  is 

performed  for  Pilgrim  and  all  indicated  safety  modifications 

are  implemented.   'Jntil  this  occurs,  the  operation  of  the  olant 

would  oose  an  unreasonable  threat  to  puolic  health  and 


;  a  r  e  t  V 


29/ 


25/   See  SUREG-1150,  Reactor  Risk  Reference  Document,  Draft  for 
Comment,  Feb.  1987,  at  4-33,  4-39. 

2_6/   Affidavit  of  Steven  C.  Sholly  (attached  hereto  as 
Attachment  1 ) . 

22/   I_d. 

28/   Id. 
29/   Id. 


13  - 


356 


Tne  w-ov-ernor  an  3  the  Attorney  "er.  eral  are  avare  -'".a"  :-.  e 
M.RC  has  to  date  declined  to  order  -^itigative  -^odi  f  icat  l  o-:3  for 
.^ark  I  design  plants. —    They  sab^iit,  however,  that  the 
evidence  presented  here  --  the  comomation  of  extre-nely 
vulnerable  cont ai ment  structures  and  a  larqe  oopulation 
surrounding  the  plant  --  precludes  application  of  'I'JREG- 11 50 '  s 
finding  that  the  probaoility  of  a  large  reactor  accident  witn 
early  fatalities  is  extre'nely  remote.   The  'rjREG-1150  findings 
do  not  reflect  the  amalgam  of  risks  posed  by  Pilgrim. 

3E:co.  has  proposed  a  number  of  modifications  as  remedial 
actions  for  the  plant's  design  def  iciencies  .— =■   These 
actions  do  not,  however,  address  the  inherent  defects  of  the 
plant's  design  m  any  real  -^ay.   The  Governor  and  the  attorney 
General  do,  however,  submit  that  through  its  so-called  "safety 
enhancement  program,"  3SCo.  has  put  the  ~:9stion  of  the 
aooropriate  modifications  to  be  made  to  remedy  the  defects  of 
the  Mark  I  design  in  issue. 


30/   Z  .  g  .  ,  3oston  "dison  Company  (Pilgrim  'luclear  Station), 
55-37-14,     -IRC     (1937)  (slip  at  31-32). 


31/   Letter  with  enclosures  dated  July  8,  193'',  from 
Mr.  Ralph  G.  =3icd,  Senior  Vice  President-'^luc  lear ,  Boston  idisor 
Company,  to  Mr.  Steven  A.  Varga,  Director,  "Division  of  Reactor 
Proiects,  I/II,  Nuclear  Regulatory  Commission  (attached  hereto 
as  attachment  6 ) . 


14 


357 


;■  :  D  -  ' 


)F  1)^\o-.j:mz   EMiR^i--;:^  ?'^-i?\?zj-.-^s 


Withm  the  past    twelve  "nonfis,  two  authoritative 
assess::ient s  have  oeen  made  of  the  PLlgrim  Radiological 
Sneraency  Response  Plan  and  the  state  of  emergency  preparedness 
within  the  Emergency  Planning  Zone  ("EPZ")  for  Pilgrim. — 
3oth  conclude  that  the  plan  and  the  state  of  preparedness  "are 
not  adequate  to  protect  the  health  and  safety  of  the  public  m 
the  event  of  an  accident  at  the  Pilgrim  'luclear  Power 
Station."—^   3oth  also  concluded  that  the  plan  and  the  state 
of  oreparedness  have  significant  deficiencies  and  suggest 
Dotential  remedies  for  those  deficiencies  that  will  require  a 
substantial  commitment  of  time,  resources  and 


coooerat ion 


34/ 


3EC0.  has  not  quarreled  with  these 


conclusions.—^  The  Governor  and  the  Att::ney  General  submit 
that  these  conclusions  compel  immediate  artion  by  the  MRC.   The 


32/   FEMA,  "Seif-Initiated  Review  and  Interim  Finding  for  the 
pTlgrim  Nuclear  Power  Station,  Plymouth,  y.\"    (August  4,  193'') 
(hereinafter  "FEMA  Self -Ini t  lated  Review");  Secretary  of  Public 
Safety,  "Report  to  the  Governor  on  Emergency  Preparedness  for 
an  Accident  at  the  Pilgrim  Nuclear  Power  Station"  (Dece^.cer  16, 
1986)  (hereinafter  "3arry  Report" ) . 

33/   FEMA  Self-Initiated  Review  at  1-2;  3arry  Report  at  ''4. 

34/   FEMA  Self-Initiated  Review,  pp.  12-13,  19,  22,  29-32, 
4  3-44;  Barry  Reoort ,  pp.  4  7-55. 

35/   9/24/87  NRC/3EC0  Readiness  Meeting",  pp.  49-54. 


358 


36/ 
autr.  :'---^--'^-  exoer.  agen  r.es  —   agree  tnat  tnere  13  -.  o 

reasonable  assarar'.ce  that  the  public  :aT  or  will  oe  oroteoteo 

in  the  event  of  an  accident  at  Pilgri-n.   It  is,  thus,  mcu-ce-.: 

jDon  the  NRC  to  take  action  mediately  to  insure  that  no-steos 

are  taken  by  3ECo.  which  could  increase  the  likelihood  or  the 

3-7/ 
consequences  of  an  accident. — 


\.    THE  PL^NNIMG  ^ND  PREPAREDNESS  DEFICIENCIES  IDENTIFIED 
3Y  FSMA  AND  THE  ?^ASS ACH'JSETTS  EXECUTIVE  OFFICE 
OF  P'J3LIC  SAFETY 


The  deficiencies  of  the  Radiological  Enerqency  Response 
Plans  for  Pilgrim  are  manifold.   Although  the  analyses  of  FEMA 
and  the  Massachusetts  Executive  Office  of  Public  Safety  do  not 
reach  the  same  conclusions  on  all  issues,  the  following  areas 
of  substantial  deficiency  have  been  ident.fied  by  both  agencies: 

1.  the  lack  of  any  articulated  eva^iation  plans 
for  oublic  and  private  schools  =.3  well  as  day 
carecenters; 

2.  the  lack  of  any  articulated  evacuation  plans 
for  the  special  needs  population; 


16/ 
exne 

of  fs 
Fed. 
IS  e 
emer 
10  C 
Safe 
Offi 
§1  I 


FE^A  13  explicitly  recognized  by  the  Com-nission  as 
rt  Federal  authority  on  questions  of  nuclear  power 
.^o   oTiergency  preparedness  (Memorandum  of  'Jnderstan 
'Reg",  No.  75,  15,486  (April  18,  1985)  and  the  Comm 
xoressly  required  to  base  its  findings  on  off-site 
gency  issues  on  FEMA's  conclusions  concerning  sucn 
.F.R.  §50.47{ s) ( 3) .   The  Massachusetts  Secretary  of 
ty'oversees  the  Ma  -  lachusetts  Civil  Defense  Agency 
ce  of  Emergency  Planning,  which  pursuant  to  M.g.l. 
s  resoonsiole  for  the  Commonwealth's  emergency  acti 


1  s 

? 

an 


he 
ant 

ng,  5  0 
SI  on 

sues  . 
u  b  1 1  c 
d 

147, 
ties. 


2''/      -ach  s-ep  of  3ECo's  oower  ascension  plan  corresoond';  with 
"substantial"  increase  in"  the  probability  of  an  accident  at 
Pilgrim.   Affidavit  of  Steven  C.  Sholly  (attached  hereto  as 
Attachment  1 ) . 


16  - 


359 


-.  ".  ^  L  a  r  ■-.  0  1    a  -.  /  a  r  t .  ;  j  .  a  -.  e  i  3  /  a  ?  ^  :i  -  .  o  -.  t  -  a  -.  ^ 
foe  tne  tran  spor':  iepen  den.  popjlaiiop. ; 


4.   tne  lack  of  iiientifraol'?  paolic  .^helier 
the  oeacn  oooul  a"  lor. ; 


to: 


5.   tie  laci^  of  a  rsception  cen.er,  as  requir'?i 
n  tne  plan,  for  people  evacuatiiq  by  the 
nortnern  route; 

5.   the  lacK  of  real  progress  m  plannnq  and  the 
dminijtion  ;n  tne  state  of  eTiergency 
prepa  redness  .13.' 

These  are  critical  deficiencies.   The  olans  do  not  e.ven 

ourport  to  provide  any  -neasure  of  protection  for  significant 

namoers  of  people:   pre-school  and  school  age  children;  f'ose 

-vno  require  special  measures  to  transport;  and  those  without 

read/  access  to  private  transportation.   They  fail  to  address 

tne  significant  oeach  population  in  an  adequate  fashion.   Thev 

do  not  incorporate  current  or  reliable  evaluation  tine 

estimates  ("ETEIs").   Jor  io  they  mcorpor -. -.e  a  delineated 

inventory  of  identified  and  identifiable  Telters  which  are 

accessiole  to  tne  public.   Moreover  an  integral  co-^po-ent  of 

39/ 

zr.e    current  plans  --  a  nortnern  receotion  center — . 


J_3/  FZ'^A    3e  If -Initiative  Review,  -pp.    12-13,  19,  22,  29-32, 
4  3-4  4;  3arry  Report,  pp.  4  7-5  5. 


11/ 
nort 

Tne 

evac 

m  1 

recs 

woul 

desc 

woul 

~oni 

i^ev  1 


The  lack  of  a  reception  center  for 
h  is  as  worrisone  as  tne  .Tiore  genera 
lacK  of  a  northern  reception  center 
uation  from  the  Z?Z    were  successful 
ight  of  tne  assorted  planning  defici 
ived  and  followed  instructions  to  ev 
facilities  availaole  at  th 
\ccording  to  F^'.W,    aoproxi 
witnou-  facilities  at  whic 
decontaminated  if  necessar 


d  find  no 
1  n  a  1 1 0  n  . 
d  oe  left 
tored  and 
e w  at  19. 


those 
1  Ola 
1  n  d  1  c 
--  a 

a  ^  f  ■  o 

acuat 
eir  i 

mat  el 
h  to 
■/•   I 


eva 

ates 

s  -- 
e  to 
es  la 
y  60 
r  eg  i 


c  u  a  1 1 

g  fai 

t  n  a  - 

1  c  as 
thos 
the 
nated 
,0  00 
ster  , 
Self- 


ng  to 
1  ires , 

3  '/  a  n 

3  U  -^  O  t 

e  who 
north 

p  e  o  o  1  ■ 
oe 


ion 


ated 


17 


360 


--    :3    ^  IS  i-.'.z    a.t^aetr.er.       rmaiLy,    orrs.te    exerr.sea    ar-. :: 
drills    --    the    most    effective    "neans    of    assari^.q    o  reoa  rei-.es  3 
nave    not    been    held    m    years. 


3.  the:  c'Jsssmt  status  of  planning  and  preparedness 


The  specific  functional  deficiencies  m  the  first  four 
areas  enunerated  above,  as  well  as  the  functional  areas  m 
which  work  .Tiust  be  done  before  any  det  er-nmat  ion  can  be  -nade  if 
adequate  plans  can  be  developed,  encompass  the  entire  set  of 
tasks  required  for  adequate  planning  and  preparedness: 
1.    Identification/EstiTiation  of  populations; 
Identification/Estimation  of  resources; 


2. 

3. 


Develop  plans  for  emergency  actions  to  be 
tai^en  for  each  population  with  potentially 
available  resources; 


4.  Obtain  commitments  for  require:  resources; 

5.  Provide  education/information  "o  public; 

6.  Conduct  exercises/drills . 

At  oresent,  it  apoears  that  the  school/daycare  oooulation 

nas  oeen  identified  but  that  the  special  needs  and  transport 

4  "I  /      , 
deoendent  populations  have  not .— ^    Preliminary  estimates  o. 

the  resources  potentially  available  to  evacuate  these 

populations  have  now  oeen  obtained,  but  neither  plan 

development  nor  obtai-.-ng  commitments  of  resource  availability 


41  / 


can  orocee 


ed  m  the  absence  of  reliable  ETEs. — 


£0/   Executive  Summary  of  the  Reaort  on  E-ergencv  Preparedness 
ror  an  Accident  at  Pilgrim  Power  Station)  (October  15,  193'') 
Thereinafter  "3arry  Report  Update"),  p.  2. 

41/   Id.  'at  2. 


-  13  - 


361 


While  3r:co.  has  recently  --  ^jgast  13,  193^  --  del.;erei  an 
ETE  stady  to  the  Commonwealth's  puoiic  safety  officials,— 
the  document  is  still  oeing  reviewed  by  those  officials  a-,i 
preliTiinary  analysis  has  uncovered  shortcomings  that  will 
necessitate  further  work.   It  is,  thus,  unlikely  that  final 

ETEs  will  be  available  withm  the  irimediate  future  for  use  m 

4  3/ 
developing  specific  plans. —   This  shortcoming  is  critical. 

A  consequence  of  the  unavailability  of  reliable  ETEs  is  that 

emergency  planning  is  effectively  on  hold.   Even  when  the  ta3< 

of  identifying/estimating  populations  and  resources  is 

completed,  radiological  emergency  planning  cannot  in  any  real 

sense  proceed  without  reliable  ETEs  and  a  traffic  management 

plan.   ^s  FEMA  and  the  NRC  well  recognize,  a  realistic  set  of 

ETEs  is  an  essential  element  of  a  workaol^  emergency  plan.   See 

Cincinnatti  Gas  5.  Electric  Company  (Wm.  -: .  Zimner  Nuclear  Power 

Station,  Unit  No.  1),  ALA9-727,  17  NRC  76:,  770-71  (1983). 

With  respect  to  the  beach  population,  orelimmary 

population  estimates  and  sheltering  data  have  oeen  provided  to 

the  Commonwealth's  public  safety  officials  out,  at  least  m  the 

case  of  the  sheltering  survey,  these  materials  have  oeen  found 


4  2/   KLD  Associates,  Pilgrim  Station  Evacuation  Time  Estiiates 
and  Traffic  Management  Plan  "Jodate  (Final  Draft  for  Review) 
August  18,  1987. 

43/   3arry  Reoort  Uodate,  p.  2. 


-  19  - 


362 


4  4/' 
Z3    se  .".  a::-ej_:i-_e  fjc  plan ". .-.  g  p^rpDses.  — ^' 

\5a1r:,  plan  develop^er.z    and  resojrie  avai'-aoili*:/  co-^^it"?-. •: 

■njcp.  less  public  ed  jcat  ion/ in.f  or-nai  ion  efforts  and 

exercises /drills,  cannot  proceed  asefully  wit  ho at  reliaole 

43/ 
final  EIEs  and  sheltering  data. — 

.Jo  replacement  site  for  a  northern  reception  center  has 

46/ 
oeen  found —   and  no  detemmation  has  yet  been  made  whet  he: 

an  emergency  plan  incorporating  only  two  reception  centers 

47/ 
would  provide  an  aaequate  assurance  of  protection. — 


44/   3arry  Report  Update ,  p.  2;  Letter  with  enclosures  from 
Rooert  J.  3oulay,  Director,  Massachusetts  Civil  Defense  ^gencv, 
dated  Sepcemoer  13,  1937,  to  Ralph  C.  3ird,  Executive  Vice 
President-Nuclear,  Boston  Edison  Company  (attached  hereto  as 
Attacnment  7  ) 


45/   3arry  Report  Jpdate ,  p .  2 ;  See  also  --  'A    Self-Init: 

Review  at  26-27: 

3efore  FEMA  and  the  RAC  can  make  a  -.eterminat ion 
on    tnis  (whetner  protective  actions  ^or  thebeach 
population  are  or  readily  can  be  made  adequate) 
It  must  receive  the  following  infornation: 


1) 

beac 

anal 

numo 

the 

geog 

of  t 

Che 

bull 

popu 

capa 

dist 

are 

clea 

and 

aoor 


an  J 

nes 

ysis 

er  o 

numo 

raph 

ne  1 

oeac 

ding 

lati 

citi 

ance 

not 

ciy 

lett 
oor  1 


pda 
and 

of 

f  ? 
er 
ica 
eng 
h  p 
s  a 
on 
es 
s  f 
ope 
st  a 
e  r  s 
ate 


ted 
tne 
the 
erma 
of  d 
1  di 
th  o 
opul 
vail 
at  e 
of  t 
rom 
n  CO 
te  h 
of 


geog 
ir  c 

oea 
nent 
ay  V 
sper 
f  ti 
at  10 
aole 
ach 
hese 
tne 

the 
ow  t 
a::re 


raphical 
apacity ; 
ch  popula 

and  temo 
isi tors , 
SI on;   3  ) 
me  It  wou 
n ;  and  4  ) 

for  shel 
beach,  m 

bui Iding 
beaches . 

public, 
hey  will 
ement  mus 


d  '^  s  c 
2) 

t  ion 
orar 
toge 

an 
Id  t 

a  1 
ten 
clud 
s  an 

If 

be  m 
t  oe 


r ipt  10 
a  deta 
,  mcl 
V  r  e  ^  1 
the:  w 
update 
ake  t  :> 
ist  of 
ng  tne 
inq  th 
d  t nei 
these 
plans 
ade  ac 
obt  ai 


n  0 

lied 

jdin 

dent 

1  th 

d  es 

eva 

sui 

oea 


«  t-  ha 


q  -- 

s  a 
the 
t  im 
cua 
tab 
ch 


he 
nd 

ate 


oui  i 
must 
cess 
ned 


cmgs 

lole 
as 


46/ 


see 


42/   9/24  MRC/3EC0.  Readiness  Meeting,  p.  52.   3u' 
FEMA  Seif-Init  lated  Review  at  19  (The  use  of  only  two 


reception  centers 
feasiole.") . 


IS  not  likely  to  be  logistically 
-  20  - 


363 


r  :  n  a  ".  1  /  ,  i  -.  i  r. e  a d s e n  r  ?  of  -. e w  plans,  ?  ^ o  I  ■_  c 
mf  or.Tiacion/educaci  on  efforts  and  exer  ci  ses/ir  :  1 1  3  canno-:,  -.v 
jefmition,  occur.   There  are  no    plans  to  •.nfor-n  -.he  ouo".:?  -;- 
exercises,  Tiacn  less  to  exercise.   Although  the  provisions  0" 
10  C.r.i^.  Part  50,  Appendix  S,  Section  IV.F.  require  that  a 
full  participation  oiennial  emergency  oreparedness  exercise  -or 
Piigrm  oe  neld  this  year,   the  MRC  is  presently  considerim  a 
request  from  3£Co.  for  a  one-tme  exemption  from  that 
requirement  to  allow  the  exercise  to  be  postponed  to  the  second 
quarter  of  1988.—'' 

17.   COriCLJSIDN 

In  light  of  all  of  the  foregoing  deficiencies  of  the 
current  state  of  e^nergency  planning  and  preparedness,  as  veil 
as  tne  suostantial  questions  raised  herei-  roncerninq  the 
managerial  aoility  of  the  licensee,  3ECo.,  and  the  safety  of 
the  Pilgrim  reactor,  the  Governor  and  Attorney  General  submit 
that  the  :JSC  must  take  action  pursuant  to  10  C.  F . ' .  <;2.202  to 
insure  tnat  3SCo.  does  not  take  any  action  tnat  could  increase 
eitner  the  ris<  or  the  consequences  of  an  arcident  at  PilTri". 

Since  tnat  Pilgrim  is  a  3S  "larK  I  design  reactor,  and  the 
£?Z  population  at  tnis  plant  is  among  the  nighest  m  the 
country,  it  is  evident  that  the  deficiencies  m  emergenrv 
planning  and  preparedness  are  significant  for  Pilgrim.   These 


43/   Letter  ^itn  enclosures  dated  Septemcer  13,  1937,  from 

Mr.  Ralph  G.  3ird,  Senior  Vice  President-Nuclear,  Boston  "diso- 

Company,  to  :IRC    (attacned  hereto  as  Attachment  3). 


21 


364 


jgf_j.-;-.  r.es  are  so  suos-antial  and  t'-.eir  poteitial 
ratifications  are  3D  significant,  tl^a':  it  is  i-npossiol?  to 
conclade  that  any  interim  compensating  actions  have  or  can  oe 
ta<en.   T"-.e  :JRC' s  regulations  leave  it  no  course  other  than 
issuing  an  order  modifying  3ECo's  license  to  extend  the  curre- 
shut  down  pending  the  outcome  of  a  full  hearing  on  the 

significant  outstanding  safety  issue-  and  the  development  and 

•'  4  9/ 

certification  oy  the  Governor  of  adequate  emergency  plans. — 

Respectively  submitted, 


James  M.  Shannon 
Attorney  General 
Commonwealth  of  *1assachuset  t  s 


Michael  S.  Dukakis 

Governor 

Commonwealth    -f    "Massachusetts 

■Dated:       Octocer    .5,     1937 


4  9/      Compare    n    C.r.S.    §50.54(s)(2)(ii): 

...  In  determining  whether  a  shutdown  or  other 
enforcement  action  is  appropriate,  the  Commission 
3r-.all  take  into  account,  among  other  factors, 
■,,-a-ner  the  licensee  can  demonstrate  to  the 
:o--i33ion'3  satisfaction  that  the  deficiencies 
m  t ne  olan  are  not  significant  for  the  plant  m 
question,  or  that  adequate  interim  compensating 
actions  have  been  or  will  be  taken  oromotly,  or 
that  there  are  other  comoelling  reasons  for 
continued  operation. 


-  22  - 


365 


APPENDIX     I:        BECo.     Sa,L?    HISTORY    T'lB'JLATIOM 


Inspec . 
Period 

Plant 
Oper . 

2 

Radiol . 
Control 

3 

Maint . 

Sarveil . 

Fire 
Prot. 

2 

£  Tie  toe  ". . 
P  r  e  D  a  r  e  -i 

01/01/80 
12/31/30 

2 

2 

2 

09/01/80 
08/31/81 

3 

2 

3 

2 

2 

1 

09/01/31 
06/30/82 

3 

2 

2 

2 

3 

1 

07/01/32 
06/30/83 

2 

2 

2 

1 

1 

1 

07/01/83 
09/30/84 

2 

3 

1 

1 

2 

3 

10/01/84 
10/31/85 

3 

3 

2 

2 

- 

3 

11/01/85 
01/31/87 

2 

3 

2 

] 

3 

2 

I  ".spec. 
Period 

Secur  . 
Saf egds 

Out. 
Mod. 

Mqt  . 
Act 

Licen. 
Activ, 

Eng/C 
Tech. 

:orp 
Sup 

Train 
Qual .Ef 

Quality 
A  s  s  u  r  a  n 

01/01/30 
12/31/80 

2 

3 

- 

- 

- 

3 

09/01/80 
03/31/31 

2 

2 

- 

- 

— 

3 

09/01/31 
06/30/32 

2 

2 

2 

- 

— 

~ 

07/01/82 
06/30/33 

2 

- 

1 

- 

- 

"" 

07/01/83 
09/30/84 

2 

1 

1 

- 

— 

~ 

10/01/34 
10/31/35 

2 

1 

1 

- 

— 

"• 

11/01/35 
01/31/37 

3 

1 

2 

1 

2 

3 

i 


366 


APPE^4DIX  II:   3ECo.  VIOLATIONS  TABULATIONS 


SEVERITY  LEVEL  III  VIOLATIOHS:   9/1/81-1/31/37 
Functional  Area  1981   1982   1983   1984   1985   198( 


.33' 


?lant  Operations 
Radiological  Controls 
Mainenance 
Sar vei 1 lance 
rire  Protection 
Emergency  Preparedness 
Security/Safeguards 
Outage  Mgt  . . . 
Licensing  Activities 
Training  ...  Eff  ness 
Assurance  of  Quality 
Engineer/Corp.  Support 


Severity  Level 


3ECo.  VIOLATIOMS  3Y  SEVERITY  LEVEL:   9/1/81-1/31/87 
31/32   82/33   33/84   34/35   85/87 


I 

II 

in 

7 

1 

1 

2 

1 

IV 

9 

9 

13 

17 

21 

V 

20 

20 

6 

5 

6 

VI 

2 

Deviations 

2 

3 

I 

3 

1 

Total  Violations 

40 

33 

26 

27 

29 

367 


UNITED  STATES  OF  AMERICA 
NUCLEAR  REGULATORY  COMMISSION 


BEFORE  THE  COMMISSION 


In  the  matter  of 

BOSTON  EDISON  COMPANY 

(Pilgrim  Nuclear  Power  Station,  Unit  1) 


Docket  No.  50-293 


AFFIDAVIT  OF  STEVEN  C.  SHOLLY 


Steven  C.  Sholly,  being  on  oath,  deposes  and  says  as  follows: 

I  am  an  Associate  Consultant  with  MHB  Technical  Associates,  1723  Hamilton 
Avenue,  Suite  K,  San  Jose,  California,  95125.  A  statement  of  my  professional 
qualifications  is  attached  hereto  and  marked  Attachment  A.  In  brief,  I  have 
more  than  six  years  experience  in  the  review,  analysis,  interpretation,  and 
application  of  probabilistic  risk  assessment  to  the  analysis  of  safety  issues 
related  to  commercial  nuclear  power  plants,  including  issues  related  to 
radiological  emergency  planning.  I  have  served  as  a  member  of  the  peer 
review  group  for  the  NRC  publication  NUREG-1050  (1984)  ^Probabilistic  Risk 
Assessment  rPRA)  Reference  Document.  September  1984),  and  have  more 
recently  sen/ed  as  a  member  of  the  Containment  Performance  Design 
Objective  Workshop,  the  Panel  on  ACRS  Effectiveness  (1985),  and  the  Sei^ere 
Accident  Policy  Implementation  External  Events  Workshop  (1987).  I  have 
previously  testified  as  an  expert  witness  on  probabilistic  risk  assessment  and 
emergency  planning  matters  in  NRC  proceedings  on  the  Catawba  Units  1  and 
2,  Indian  Point  Units  2  and  3,  and  Shoreham  Unit  1  nuclear  plants,  and  also  m 
the  Public  Inquiry  regarding  the  proposed  Sizewell-B  nuclear  plant  in  the  United 
Kingdom     In  addition,  I  have  co-authored  two  major  reviews  of  source  term 


368 


-2- 


and  risk  estimate  issues  published  in  NRC  reports  NUREG-0956  and  NUREG- 
1150.  I  have  also  performed  reviews  of  various  technical  aspects  of  the 
Shoreham,  Limerick,  Indian  Point,  Sizewell,  Zion,  Seabrook,  Millstone-3,  and 
Oconee-3  probabilistic  risk  assessments  and  the  Vermont  Yankee 
Containment  Safety  Study. 

f^HB  Technical  Associates  ("MHB")  has  been  requested  by  the  Nuclear  Safety 
Division,  Department  of  the  Attorney  General,  The  Commonwealth  of 
fj/lassachusetts,  to  evaluate  the  increase  in  risk  resulting  from  a  startup 
program  for  return  to  power  from  the  current  refueling  and  modifications 
outage  for  the  Pilghm  Nuclear  Pov\er  Station,  Unit  i  (PNPS-i). 

In  its  current  configuration  (refueled)  and  considering  the  duration  of  the 
current  shutdown,  Pilgrim  currently  poses  very  little  i-  -k  to  the  public  health  and 
safety.  This  is  due  to  the  multiplicity  of  systems  theoretically  available  to  inject 
water  into  the  reactor  vessel  and  due  to  the  low  decay  heat  level  present  in  the 
fuel.  In  the  event  of  a  core  heatup  transient  with  the  plant  in  its  current 
configuration,  considerable  time  would  elapse  between  initiation  of  coolant  loss 
and  the  onset  of  fuel  damage,  time  during  which  measures  could  be  taken  to 
initiate  coolant  makeup  and/or  other  recovery  and  mitigative  actions. 
Moreover,  in  theory  a  longer  time  period  is  available  within  which  to  implement 
offsite  protective  actions  due  to  the  slower  accident  progression  time 
compared  with  accidents  at  higher  power  levels. 

Boston  Edison  Company  (BECO),  the  licensee  for  Pilgrim,  currently  envisions 
restart  power  ascension  program  with  a  minimal  number  of  hold  points.  In 
brief,  BECO  proposes  to  institute  holds  on  restart  (pending  approval  from  NRC 
in  accord  with  Confirmatory  Action  Letter  No.  86-10),  recovery  from  reactor 
mode  switch  testing  prior  to  conducting  a  test  for  shutdown  from  outside  the 
control  room,  and  prior  to  movement  of  the  scram  set  point  above  95%  power. 
[Sgfi,  Boston  Edison  Company,  Pilgrim  Nuclear  Power  Station  Restart  Plan. 
pages  IV-29  to  IV-31.]  The  details  of  the  power  ascension  program  in 
Attachment  13  of  the  Pilgrim  Nuclear  Power  Station  Restart  Plan  have  not  yet 
been  provided. 


369 


My  current  understanding  of  the  BECO  power  ascension  program  is  that  the 
program  would  result  in  a  relatively  rapid  ascension  from  the  current  shutdown 
condition  to  full-power  operation.  In  so  doing,  the  risk  to  the  public  health  and 
safety  posed  by  operations  at  the  Pilgrim  plant  will  be  increased  markedly. 

The  Commission  has  concluded  generally  that  the  risks  from  5%  power 
operation  are  negligible.  [See,  for  example,  SECY-84-155,  12  April  1984,  and 
attachments;  and  letter  dated  15  June  1984  from  Nunzio  J.  Palladino  to  Hon 
Edward  J.  Markey,  and  attachments.]  The  evaluations  upon  which  the 
Commission  has  drawn  these  conclusions,  however,  were  for  plants  with  very 
little  operating  history  and  no  spent  fuel  pool  inventory.  Clearly,  Pilgrim  is 
different  in  this  regard,  with  a  substantial  long-half-life  fission  product  inventory 
present  m  both  the  refueled  reactor  core  and  the  spent  fuel  pool.  Moreover, 
these  evaluations  did  not  consider  the  unique  risks  posed  by  accidents 
resulting  from  externally-initiated  events  (specifically,  in  this  case,  seismic 
events).  In  my  opinion,  the  presence  of  more  than  1 100  spent  fuel  assemblies, 
prior  operation  of  two-thirds  of  the  core  at  equivalent  full  power  for  most  of  an 
operating  cycle,  and  the  matter  of  external  events  render  the  circumstances  at 
Pilgrim  sufficiently  different  from  those  previously  evaluated  for  5%  power 
operation  that  the  previous  evaluations  understate,  perhaps  significantly,  the 
risk  posed  by  operation  of  Pilghm  at  5%  of  full  power.  This  conclusion  is 
further  supported  by  the  likelihood  that  the  primary  containment  will  not  be 
inerted  until  operation  above  5%  power  is  commenced.  In  my  opinion,  virtually 
any  severe  accident  at  5%  power  with  the  containment  de-inerted  will  result  in 
early  containment  failure  (due  to  hydrogen  burn  or  hydrogen  detonation  m  the 
primary  containment,  and/or  other  causes). 

As  power  level  increases,  risk  to  the  public  increases.  This  is  due  to  several 
factors,  including  a  marked  increase  in  volatile  fission  product  inventory  and  a 
marked  increase  in  decay  heat  level,  which  results  in  accident  progression 
times  which  are  much  shorter  than  at  low  power  levels.  This  reduces  the 
amount  of  time  available  for  implementation  of  recovery  and/or  mitigation 


370 


-4- 


actions  and  reduces  the  amount  of  time  available  to  implement  offsite 
protective  measures. 

A  full-scope  probabilistic  risk  assessment  for  the  Pilgrim  plant  has  been  in 
progress  for  several  years.  It  is  my  understanding  that  this  study  is  nearly 
completed.  It  is  my  expectation  that  this  study  will  identify  seismic  initiating 
events  as  a  significant  contributor  to  core  melt  frequency  (i.e.,  contributing  10% 
or  more  to  core  melt  frequency  from  all  causes).  This  expectation  is  based  on 
my  familiarity  with  seismic  risk  assessments  performed  on  similar  designs  and 
performed  on  other  plants  in  the  general  region  of  Pilgnm  (e.g.,  Shoreham, 
Seabrook  Units  1  and  2,  f^illstone  Unit  3,  and  Limerick  Units  1  and  2). 
Seismically-initiated  accident  sequences  are  accompanied  by  potentially 
severe  impacts  on  offsite  emergency  response  even  when  there  are  fully- 
approved  and  operational  emergency  plans.  In  the  case  of  Pilgrim,  the  current 
status  of  emergency  planning  is  such  that  there  is  not  adequate  assurance  that 
protective  actions  can  and  will  be  taken  in  the  event  of  an  accident.  Given  the 
more  severe  conditions  of  a  seismically-initiated  accident  scenario,  this 
conclusion  is  all  the  more  applicable. 

A  study  of  risk  at  25%  power  for  the  Shoreham  nuclear  plant,  which  possesses 
a  nuclear  steam  supply  system  which  is  grossly  similar  to  Pilgrim,  Indicates  that 
the  core  melt  frequency  for  operations  at  up  to  25%  of  full  power  may  not  differ 
dramatically  from  the  core  melt  frequency  at  full  power.  The  25%  power  PRA 
estimates  a  core  melt  frequency  of  2.8  x  10'^  per  reactor-year.  [See.  E.T. 
Burns,  S.  Mays,  and  T.  Mairs,  Probabilistic  Risk  Assessment  of  the  Shoreham 
Nuclear  Power  Station:  Initial  Power  Operation  Limited  to  25%  of  Full  Power. 
Delian  Corporation,  prepared  for  Long  Island  Lighting  Company,  April  1987, 
page  4-12.]  The  full  power  PRA  analyses  for  Shoreham  estimated  a  core  melt 
frequency  of  about  6.5  x  10'^  per  reactor-year.  [See.  Science  Applications, 
Inc.,  Final  Report:  Probabilistic  Risk  Assessment.  Shoreham  Nuclear  Power 
Station,  prepared  for  Long  Island  Lighting  Company,  24  June  1983,  page  4; 
and  V.  Joksimovich,  et  al.,  Maior  Common-Cause  Initiating  Events  Study: 
Shoreham  Nuclear  Power  Station.  NUS  Corporation,  NUS  Report  No.  NUS- 
4617,  prepared  for  Long  Island  Lighting  Company,  February  1985,  page  1-8] 


371 


This  represents  less  than  a  factor  of  three  difference  in  the  likelihood  of  a  core 
melt  accident  at  25%  power  versus  full  power.  Although  this  assessment  is  for 
Shoreham  and  not  for  Pilgrim,  it  suggests  that  the  likelihood  of  an  accident  is 
not  markedly  different  for  25%  power  versus  100%  power. 

10.  Further,  a  limited-scope  PRA  of  Shoreham  at  5%  power  was  prepared  for 
LILCO.  This  study,  which  did  not  include  external  events,  concluded  that  the 
core  melt  frequency  for  5%  power  operation  was  about  4.9  x  10'^  per  reactor- 
year.  [See.  Delian  Corporation  and  Science  Applications,  Inc.,  Probabilistic 
Risk  Assessment.  Shoreham  Nuclear  Power  Station.  Low  Power  Operation  Up 
to  5%  of  Full  Power,  prepared  for  Long  Island  Lighting  Company,  draft,  May 
1984,  page  78.]  This  indicates  that  core  melt  frequency  at  5%  power  is 
significantly  reduced  from  25%  power  or  full  power,  by  a  factor  of  roughly  20, 
but  not  nearly  as  significantly  reduced  as  previously  predicted  by  the  NRC  staff, 
which  predicted  a  reduction  factor  of  1 ,000  or  more.  1/  Moreover,  the  5% 
power  reduction  factor  of  20  is  an  underestimate  since  the  5%  power  estimates 
do  not  include  external  events. 

11.  The  5%,  25%,  and  100%  power  PRA  studies  for  Shoreham  indicate,  in  my 
opinion,  that  the  core  power  level  for  Pilgrim  will  have  at  best  a  moderate 
impact  on  the  likelihood  of  an  accident.  Considering  the  uncertainties  involved, 
the  likelihood  of  an  accident  may  be  nearly  indistinguishable  at  the  various 
power  levels  indicated  above.  Moreover,  the  Shoreham  results  are  lower  than 
the  core  melt  frequency  estimates  for  many  other  plants.  A  Brookhaven 
National  Laboratory  review  of  the  Shoreham  PRA  for  internal  events  only 
estimated  a  core  melt  frequency  of  1  x  10"*  per  reactor-year.  An  average  value 
for  full-scope  PRAs  completed  to  date  is  of  the  order  of  3  x  10"*  per  reactor- 
year. 


1/  The  NRC  staff,  in  SECY-84-156,  predicted  core  melt  frequency  reduction  factors 
for  various  classes  of  BWR  accidents  ranging  from  1,000  to  100,000.  [See, 
SECY-84-1 56.  Enclosure  1 ,  "Staff  Review  Process  for  5  Percent  Power  Operation", 
page  2.]  Thus,  in  the  aggregate,  the  NRC  staff  would  have  expected  a  core  melt 
frequency  reduction  of  at  least  1,000,  compared  with  the  Shoreham  value  of  20. 
The  results  for  Shoreham  indicate  a  reduction  factor  approximately  50  times  less 
than  the  NRC  staff  expected  based  on  engineenng  judgment. 


372 


12,  These  results  are  especially  significant  for  a  plant  with  a  containment  design 
similar  to  Pilgnm.  Pilgrim  employs  a  steel  Mark  I  pressure  suppression 
containment.  Such  containments  have  been  estimated  m  a  variety  of  studies 
sponsored  by  IDCOR,  NRC,  and  utilities  to  have  an  early  containment  failure 
probability  --  given  a  severe  accident  --  in  a  range  from  10-90%.  This  means 
that  there  is  a  significant  chance  that,  given  a  severe  accident,  the  accident  will 
be  accompanied  by  a  large  early  release  of  radioactivity  to  the  environment. 

13.  The  Pilgrim  plant,  like  all  tVlark  I  containment  design  plants,  also  employs  a 
secondary  containment,  usually  referred  to  as  a  reactor  building.  This 
structure  is  not  designed  to  withstand  the  high  internal  pressures  which  would 
accompany  a  severe  accident,  and  is  unlikely  to  survive  in  a  leak-tight  condition 
following  primary  containment  failure.  High  pressure  in  the  secondary 
containment  due  to  a  severe  accident  would  be  produced  by  a  combination  of 
blowdown  due  to  primary  containment  failure,  primary  containment  leakage, 
phmary  containment  venting,  and  burning  of  combustible  gases.  Indeed,  Mark 
I  plants  are  designed  with  both  internal  and  external  "blow-out  panels"  which 
are  designed  to  relieve  pressure.  In  the  case  of  Pilgrim,  there  are  blow-out 
panels  at  the  refueling  deck  elevation  which  relieve  pressure  directly  to  the 
environment.  In  my  opinion,  there  is  little  basis  for  assuming  that  releases  from 
the  primary  containment  will  be  significantly  mitigated  by  the  presence  of  the 
secondary  containment. 

13  Based  on  the  above  considerations,  it  is  my  opinion  that  Pilgrim  Unit  1  should 

not  be  restarted  until  the  offsite  emergency  response  plans  are  upgraded  and 
evaluated  to  adequately  protect  the  public  health  and  safety.  Further,  it  is  my 
recommendation  that  BECO  be  required  to  promptly  submit  the  Pilgrim 
probabilistic  risk  assessment  study  to  the  NRC  for  public  review  and  evaluation 
prior  to  restart.    The  review  of  such  a  study  should  indicate  whether  there 


373 


-7- 


remain  significant  operational  risks  which  must  be  amelioriated  in  order  to 
provide  adequate  protection  to  the  public  health  and  safety, 

0 


Steven  C  Sholly 
Associate  Consultant 


GENERAL  ACKNOWLEDGMENT 


State  ot_ 


County  ot 


t  Ji  Z,-.-.,^  ^ 


On  this  the 


^^  day  01         (\2^^ZZZ^^ 


'9£z  oetore  f^e 


M^^^^ 


OFFICIAL  SEAL 

MrUNA  L  BARRY 

NOTARY  PU8UC  •  CAUFOBNIA 

3Mir«  cum  couirrr 

My  lTtT*(l     §ipir«s    )UW 


the  undersigned  Notary  Public   aersonally  appeared  > 


personally  <nown  to  me 
•^proved  to  me  on  the  Basis  of  satisfactory  evidence 

to  De  the  personisi  whose  nameisi  /  J sutiscnped  to  the 

within  instrument  and  acknowledged  that  h  <;  pxprnipn  it 

WITNESS  my  hand  and  official  seal 


NATIONAL  NOTAOY  »SS0CI«TI0S    .    J  301  J  Ve^lu'a  81.0     .    OQ   Bo.  4625    ■    Aoooanfl -.«»  CA    m,ili . 


374 


ATTACHMENT  A 


PROFESSIONAL  QUALIFICATIONS  OF  STEVEN  C.  SHOLLY 


STEVEN  C.  SHOLLY 

MHB  Technical  Associates 

1723  Hamilton  Avenue 

Suite  K 

San  Jose,  California     95125 

(408)   266-2716 


EXPERIENCE 


September  1985  -  PRESENT 

Associate  -  MHB  Technical  Associates,  San  Jose,  California 

Associate  in  energy  consulting  firm  that  specializes  in  technical  and 
economic  assessments  of  energy  production  facilities,  especially  nuclear, 
for  local,  state,  and  federal  governments  and  private  organizations.  MHB 
is  extensively  involved  in  regulatory  proceedings  and  the  preparation  of 
studies  and  reports.  Conduct  research,  write  reports,  participate  in 
discc'ery  process  in  regulatory  proceedings,  develop  testimony  and  other 
documents  for  regulatory  proceedings,  and  respond  to  client  inquiries. 
Clients  have  included:  State  of  California,  State  of  New  York,  State  of 
II 1 inois. 

February  1981  -  September  1985 

Technical  Research  Associate  and  Risk  Analyst  -  Union  of  Concerned  Scien- 
tists, Washington.  D.C. 

Research  associate  and  risk  analyst  for  public  interest  group  based  in 
Cambridge,  Massachusetts,  that  specializes  in  examining  the  impact  of  ad- 
vanced technologies  on  society,  principally  in  the  areas  of  arms  control 
and  energy.  Technical  work  focused  on  nuclear  power  plant  safety,  with 
emphasis  on  probabilistic  risk  assessment,  radiological  emergency 
planning  and  preparedness,  and  generic  safety  issues.  Conducted 
research,  prepared  reports  and  studies,  participated  in  administrative 
proceedings  before  the  U.S.  Nuclear  Regulatory  Commission,  developed 
testimony,  aniayzed  NRG  rule-making  proposals  and  draft  reports  and 
prepared  conments  thereon,  and  responded  to  inquiries  from  sponsors,  the 
general  public,  and  the  media.  Participated  as  a  member  of  the  Panel  on 
ACRS  Effectiveness  (1985),  the  Panel  on  Regulatory  Uses  of  Probabilistic 
Risk  Assessment  (Peer  Review  of  NUREG-1050;  1984),  Invited  Observer  to 
NRC  Peer  Review  meetings  on  the  source  term  reassessment  (BMI-2104;  1983- 
1984),  and  the  Independent  Advi-sory  Connittee  on  Nuclear  Risk  for  the 
Nuclear  Risk  Task  Force  of  the  National  Association  of  Insurance 
Commissioners  (1984). 


-1- 


375 


January  1980  -  January  1981 

Project  Director  and  Research  Coordinator  -  Three  Mile  Island  Publ ic 
Interest  Resource  Center,  Harrisburq,  Pennsylvania       ' 

Provided  administrative  direction  and  coordinated  research  projects  for  a 
public  interest  group  based  in  Harrisburg,  Pennsylvania,  centered  around 
issues  related  to  the  Three  Mile  Island  Nuclear  Power  Plant.  Prepared 
fundraising  proposals,  tracked  progress  of  U.S.  Nuclear  Regulatory  Com- 
mission, U.S.  Department  of  Energy,  and  General  Public  Utilities  activi- 
ties concerning  cleanup  of  Three  Mile  Island  Unit  2  and  preparation  for 
restart  of  Three  Mile  Island  Unit  1,  and  monitored  developments  related 
to  emergency  planning,  the  financial  health  of  General  Public  Utilities, 
and  NRG  rulemaking  actions  related  to  Three  Mile  Island. 

July  1978  -  January  1980 

Chief  Biological  Process  Operator  -  Wastewater  Treatment  Plant,  Perry 
Township  Municipal  Authority,  Hershey,  Pennsylvania 

Chief  Biological  Process  Operator  at  a  2.5  million  gallon  per  day  ter- 
tiary, activated  sludge,  wastewater  treatment  plant.  Responsible  for  bi- 
ological process  monitoring  and  control,  including  analysis  of  physical, 
chemical,  and  biological  test  results,  procees  fluid  and  mass  flow  man- 
agement, micro-biological  analysis  of  activiated  sludge,  and  maintenance 
of  detailed  process  logs  for  input  into  state  and  federal  reports  on 
treatment  process  and  effluent  quality.  Received  certification  from  the 
Commonwealth  of  Pennsylvania  as  a  wastewater  treatment  plant  operator. 
Member  of  Water  Pollution  Control  Association  of  Pennsylvania,  Central 
Section,  1980. 

July  1977  -  July  1978 

Wastewater  Treatment  Plant  Operator  -  Borough  of  Lemoyne,  Lemoyne,  Penn- 
sylvania 

Wastewater  treatment  plant  operator  at  2.0  million  gallon  per  day  sec- 
ondary, activated  sludge,  wastewater  treatment  plant.  Performed  tasks  as 
assigned  by  supervisors,  including  simple  physical  and  chemical  tests  on 
wastewater  streams,  maintenance  and  operation  of  plant  equipment,  and 
maintenance  of  the  collection  system. 

September  1976  -  June  1977 

Science  Teacher  -  West  Shore  School  District,  Camp  HHI.  Pennsylvania 

Taught  Earth  and  Space  Science  at  ninth  grade  level.  Developed  and  im- 
plemented new  course  materials  on  plate  tectonics,  environmental  geology, 
and  space  science.  Served  as  Assistant  Coach  of  the  district  gymnastics 
team. 


-2- 


376 


September  1975  -  June  1975 

Science  Teacher  -  Carlisle  Area  School  District.  Carlisle.  Pennsylvania 

Taught  Earth  and  Space  Science  and  Environmental  Science  at  ninth  grade 
level.  Developed  and  implemented  new  course  materials  on  plate  tecton- 
ics, environmental  geology,  noise  pollution,  water  pollution,  and  energy. 
Served  as  Advisor  to  the  Science  Projects  Club. 

EDUCATION: 

B.S.,  Education,  majors  in  Earth  and  Space  Science  and  General  Science, 
minor  in  Environmental  Education,  Shippensburg  State  College,  Shippens- 
burg,  Pennsylvania,  1975. 

Graduate  coursework  in  Land  Use  Planning,  Shippensburg  State  College, 
Shippensburg,  Pennsylvania,  1977-1978. 

PUBLICATIONS: 

1.  "Determining  Mercalli  Intensities  from  Newspaper  Reports,"  Journal  of 
Geological  Education.  Vol.  25,  1977. 

2.  A  Critique  of:  An  Independent  Assessment  of  Evacuation  Times  for  Three 
Mile  Island  Nuclear  Power  Plant,  Three  Mile  Island  Public  Interest 
Resource  Center,  Harrisburg,  Pennsylvania,  January  1981. 

3.  A  Brief  Review  and  Critique  of  the  Rockland  County  Radiological  Emergency 
Preparedness  Plan,  Union  of  Concerned  Scientists,  prepared  for  Rockland 
County  Emergency  Planning  Personnel  and  the  Chairman  of  the  County  Legis- 
lature, Washington,  D.C.,  August  17,  1981. 

4.  The  Necessity  for  a  Prompt  Public  Alerting  Capability  i"  the  Plume  Expo- 
sure Pathway  EPZ  at  Nuclear  Power  Plant  Sites,  Union  of  Concerned  Scien- 
tists, Critical  Mass  Energy  Project,  Nuclear  Information  and  Resource 
Service,  Environmental  Action,  and  New  York  Public  Interest  Research 
Group,  Washington,  D.C..  August  27,  1981.  * 

5.  "Union  of  Concerned  Scientists,  Inc.,  Coiiinents  on  Notice  of  Proposed 
Rulemaking,  Amendment  to  10  CFR  50,  Appendix  E,  Section  IV. D. 3,"  Union  of 
Concerned  Scientists.  Washington.  D.C..  October  21,  1981.  * 

6.  "The  Evolution  of  Emergency  Planning  Rules,"  in  The  Indian  Point  Book:  A 
Briefing  on  the  Safety  Inyestiqation  of  the  Indian  Point  Nuclear  Power 
Plants,  Anne  Witte,  editor.  Union  of  Concerned  Scientists  (Washington. 
D.C.)  and  New  York  Public  Interest  Research  Group  (New  York.  NY),  1982. 

7.  "Union  of  Concerned  Scientists  Comments.  Proposed  Rule.  10  CFR  Part  50, 
Emergency  Planning  and  Preparedness:  Exercises,  Clarification  of  Regula- 
tions. 46  F.R.  61134."  Union  of  Concerned  Scientists,  Washington,  D.C. 
January  15.  1982.  * 


377 


8.  Testimony  of  Robert  D.  Pollard  and  Steven  C.  Sholly  before  the  Sub- 
committee on  Energy  and  the  Environment,  Committee  on  Interior  and 
Insular  Affairs,  U.S.  House  of  Representatives,  Middletown,  Pennsylvania, 
March  29,  1982,  available  from  the  Union  of  Concerned  Scientists. 

9.  "Union  of  Concerned  Scientists  Detailed  Comments  on  Petition  for  Rulemak- 
ing by  Citizen's  Task  Force,  Emergency  Planning,  10  CFR  Parts  50  and  70, 
Docket  No.  PRM-50-31,  47  F.R.  12639,"  Union  of  Concerned  Scientists, 
Washington,  D.C.,  May  24,  1982. 

10.  Supplements  to  the  Testimony  of  Ellyn  R.  Weiss,  Esq.,  General  Counsel, 
Union  of  Concerned  Scientists,  before  the  Subcommittee  on  Energy 
Conservation  and  Power,  Committee  on  Energy  and  Commerce,  U.S.  House  of 
Representatives,  Union  of  Concerned  Scientists,  Washington,  D.C.,  August 
16,  1982. 

11.  Testimony  of  Steven  C.  Sholly,  Union  of  Concerned  Scientists,  Washington, 
D.C.,  on  behalf  of  the  New  York  Public  Interest  Research  Group,  Inc.,  be- 
fore the  Special  Committee  on  Nuclear  Power  Safety  of  the  Assembly  of  the 
State  of  New  York,  hearings  on  Legislative  Oversight  of  the  Emergency  Ra- 
diologic Preparedness  Act,  Chapter  708,  Laws  of  1981,  September  2,  1982. 

12.  "Comments  on  'Draft  Supplement  to  Final  Environmental  Statement  Related 
to  Construction  and  Operation  of  Clinch  River  Breeder  Reactor  Plant'," 
Docket  No.  50-537,  Union  of  Concerned  Scientists,  Washington,  D.C., 
September  13,  1982.  * 

13.  "Union  of  Concerned  Scientists  Comments  on  'Report  to  the  County  Commis- 
sioners', by  the  Advisory  Committee  on  Radiological  Emergency  Plan  for 
Columbia  County,  Pennsylvania,"  Union  of  Concerned  Scientists,  Washing- 
ton, D.C.,  September  15,  1982. 

14.  "Radiological  Emergency  Planning  for  Nuclear  Reactor  Accidents,"  pre- 
sented to  Kernenergie  Ontmanteld  Congress,  Rotterdam,  The  Netherlands, 
Union  of  Concerned  Scientists,  Washington,  D.C,  October  8,  1982. 

15.  "Nuclear  Reactor  Accident  Consequences:  Implications  for  Radiological 
Emergency  Planning,"  presented  to  the  Citizen's  Advisory  Committee  to  Re- 
view Rockland  County's  Own  Nuclear  Evacuation  and  Preparedness  Plan  and 
General  Disaster  Preparedness  Plan,  Union  of  Concerned  Scientists,  Wash- 
ington, D.C,  November  19,  1982. 

16.  Testimony  of  Steven  C.  Sholly  before  the  Subconriittee  on  Oversight  and 
Investigations,  Committee  on  Interior  and  Insular  Affairs,  U.S.  House  of 
Representatives,  Washington,  D.C,  Union  of  Concerned  Scientists,  Decem- 
ber 13.  1982. 

17.  Testimony  of  Gordon  R,  Thompson  and  Steven  C  Sholly  on  Commission  Ques- 
tion Two,  Contentions  2.1(a)  and  2.1(d),  Union  of  Concernei  Scientists 
and  New  York  Public  Interest  Research  Group,  before  the  U.S.  Nuclear  Reg- 
ulatory Commission  Atomic  Safety  and  Licensing  Board,  In  the  Matter  of 
Consolidated  Edison  Company  of  New  York  (Indian  Point  Unit  2)  and  the 
Power  Authority  of  the  State  of  New  York  (Indian  Point  Unit  3),  Docket 
Nos.  50-247-SP  and  50-286-SP,  Decenter  28,  1982.  * 


378 


18.  Testimony  of  Steven  C.  Sholly  on  the  Consequences  of  Accidents  at  Indian 
Point  (Commission  Question  One  and  Board  Question  1.1,  Union  of  Concerned 
Scientists  and  New  York  Public  Interest  Research  Group,  before  the  U.S. 
Nuclear  Regulatory  Conmission  Atomic  Safety  and  Licensing  Board,  in  the 
Matter  of  Consolidated  Edison  Company  of  New  York  (Indian  Point  Unit  2) 
and  the  Power  Authority  of  the  State  of  New  York  (Indian  Point  Unit  3), 
Docket  Nos.  50-247-SP  and  50-286-SP,  February  7,  1983,  as  corrected 
February  16,  1983. 


* 


19.  Testimony  of  Steven  C.  Sholly  on  Commission  Question  Five,  Union  of  Con- 
cerned Scientists  and  New  York  Public  Interest  Research  Group,  before  the 
U.S.  Nuclear  Regulatory  Commission  Atomic  Safety  and  Licensing  Board,  in 
the  Matter  of  Consolidated  Edison  Company  of  New  York  (Indian  Point  Unit 
2)  and  the  Power  Authority  of  the  State  of  New  York  (Indian  Point  Unit 
3),  Docket  Nos.  50-247-SP  and  50-286-SP,  March  22,  1983.  * 

20.  "Nuclear  Reactor  Accidents  and  Accident  Consequences:  Planning  for  the 
Worst,"  Union  of  Concerned  Scientists,  Washington,  D.C.,  presented  at 
Critical  Mass  '83,  March  26,  1983. 

21.  Testimony  of  Steven  C.  Sholly  on  Emergency  Planning  and  Preparedness  at 
Commercial  Nuclear  Power  Plants,  Union  of  Concerned  Scientists,  Washing- 
ton, D.C.,  before  the  Subcommittee  on  Nuclear  Regulation,  Committee  on 
Environment  and  Public  Works,  U.S.  Senate,  April  15,  1983,  (with  "Union 
of  Concerned  Scientists'  Response  to  Questions  for  the  Record  from  Sena- 
tor Alan  K.  Simpson,"  Steven  C.  Sholly  and  Michael  E.  Faden). 

22.  "PRA:  What  Can  it  Really  Tell  Us  About  Public  Risk  from  Nuclear  Ac- 
cidents?," Union  of  Concerned  Scientists,  Washington,  D.C.,  presentation 
to  the  14th  Annual  Meeting,  Seacoast  Anti-Pollution  League,  May  4,  1983. 

23.  "Probabilistic  Risk  Assessment:  The  Impact  of  Uncertainties  on  Radi- 
ological Emergency  Planning  and  Preparedness  Considerations,"  Union  of 
Concerned  Scientists,  Washington,  D.C.,  June  28,  1983. 

24.  "Response  to  GAO  Questions  on  NRC's  Use  of  PRA,"  Union  of  Concerned  Sci- 
entists, Washington,  D.C.,  October  6,  1983,  attachment  to  letter  dated 
October  6,  1983,  from  Steven  C.  Sholly  to  John  E.  Bagnulo  (GAO,  Washing- 
ton, D.C.). 

25.  The  Impact  of  "External  Events"  on  Radiological  Emergency  Response  Plan- 
nTrTq  Considerations,  Union  of  Concerned  Scientists,  Washington,  D.C.,  De- 
cember 22,  1983,  attachment  to  letter  dated  December  22,  1983,  from 
Steven  C.  Sholly  to  NRC  Comnissioner  James  K.  Asselstine. 

26.  Sizewell  'B'  Public  Inquiry,  Proof  of  Evidence  on:  Safety  and  Waste  Man- 
agement Implications  of  the  Slzewell  PWR.  Gordon  Thompson,  with 
supporting  evidence  by  Steven  Sholly,  on  behalf  of  the  Town  and  Country 
Planning  Association,  February  1984,  Including  Annex  G,  "A  review  of 
Probabilistic  Risk  Analysis  and  Its  Application  to  the  Slzewell  PWR," 
Steven  Sholly  and  Gordon  Thompson,  (August  11,  1983),  and  Annex  0, 
"Emergency  Planning  In  the  UK  and  the  US:  A  Comparison,"  Steven  Sholly 
and  Gordon  Thompson  (October  24,  1983). 


-5- 


379 


11.  Testimony  of  Steven  C.  Sholly  on  Emergency  Planning  Contention  Numoer 
Eleven,  Union  of  Concerned  Scientists,  Washington,  O.C,  on  behalf  of  the 
Palmetto  Alliance  and  the  Carolina  Environmental  Study  Group,  before  the 
U.S.  Nuclear  Regulatory  Commission  Atomic  Safety  and  Licensing  Board,  in 
the  Matter  of  Duke  Power  Company,  et.  al.  (Catawba  Nuclear  Station,  Units 
1  and  2),  Docket  Nos.  50-413  and  50-414,  April  16,  1984.  * 

28.  "Risk  Indicators  Relevant  to  Assessing  Nuclear  Accident  Liability  Premi- 
ums," in  Preliminary  Report  to  the  Independent  Advisory  Committee  to  the 
NAIC  Nuclear  Risk  Task  Force,  December  11,  1984,  Steven  C.  Sholly,  Union 
of  Concerned  Scientists,  Washington,  O.C. 

29.  "Union  of  Concerned  Scientists'  and  Nuclear  Information  and  Resource  Ser- 
vice's Joint  Comments  on  NRC's  Proposal  to  Bar  from  Licensing  Proceedings 
the  Consideration  of  Earthquake  Effects  on  Emergency  Planning,"  Union  of 
Concerned  Scientists  and  Nuclear  Information  and  Resource  Service,  Wash- 
ington, O.C,  Diane  Curran  and  EUyn  R.  Weiss  (with  input  from  Steven  C. 
Sholly).  February  28,  1985.  * 

30.  "Severe  Accident  Source  Terms:  A  Presentation  to  the  Commissioners  on  the 
Status  of  a  Review  of  the  NRC's  Source  Term  Reassessment  Study  by  the 
Union  of  Concerned  Scientists,"  Union  of  Concerned  Scientists,  Washing- 
ton, O.C.  .  April  3,  1985.  * 

31.  "Severe  Accident  Source  Terms  for  Light  Water  Nuclear  Power  Plants:  A 
Presentation  to  the  Illinois  Department  of  Nuclear  Safety  on  the  Status 
of  a  Review  of  the  NRC's  Source  Term  Reassessment  Study  (STRS)  by  the 
Union  of  Concerned  Scientists,"  Union  of  Concerned  Scientists, 
Washington,  D.C.,  May  13,  1985. 

32.  The  Source  Term  Debate:  A  Review  of  the  Current  Basis  for  Predicting  Se- 
vere Accident  Source  Terms  with  Special  Emphasis  on  the  NRC  Source  Term 
Reassessment  Program  (NUREG-0956) ,  Union  of  Concerned  Scientists.  Cam- 
bridge, Massachusetts,  Steven  CT  Sholly  and  Gordon  Thompson,  January 
1986. 

33.  Direct  Testimony  of  Dale  G.  Bridenbaugh,  Gregory  C.  Minor,  Lynn  K.  Price, 
and  Steven  C.  Sholly  on  behalf  of  State  of  Connecticut  Department  of  Pub- 
lic Utility  Control,  Prosecutorial  Division  and  Division  of  Consumer 
Counsel,  regarding  the  prudence  of  expenditures  on  Millstone  Unit  III, 
February  18,  1986. 

34.  Implications  of  the  Chernobyl-4  Accident  for  Nuclear  Emergency  Planning 
for  the  State  of  New  York,  prepared  for  the  State  of  New  York  Consumer 
Protection  Board,  by  MHB  Technical  Associates,  June  1986. 

35.  Review  of  Vermont  Yankee  Containment  Safety  Study  and  Analysis  of 
Containment  Venting  Issues  for  the  Vermont  Yankee  Nuclear  Power  Plant, 
prepared  for  New  England  Coalition  on  Nuclear  Pollution,  Inc.,  December 
16,  1986. 


-6- 


380 


36.  Affidavit  of  Steven  C.  Sholly  before  the  Atomic  Safety 
and  Licensing  Board,  m  the  matter  of  Public  Service 
Company  of  New  Hampshire,  et  al.,  regarding  SeabrooK 
Station  Units  1  and  2  Off-site  Emergency  Planning 
Issues,  Docket  Nos .  50-443-OL  &  50-444-OL,  January  23, 
1987. 

37.  Direct  Testimony  of  Richard  B.  Hubbard  and  Steven  C. 
Sholly  on  behalf  of  California  Public  Utilities 
Commission,  regarding  Diablo  Canyon  Rate  Case,  PG&E's 
Failure  to  Establish  Its  Committed  Design  QA  Program, 
Application  Nos.  84-06-014  and  85-08-025,  Exhibit  No. 
10",935,  March,  1987. 

38.  Testimony  of  Gregory  C.  Minor,  Steven  C.  Sholly  et.  al. 
on  behalf  of  Suffolk  County,  regarding  LILCO's  Reception 
Centers  (Planning  Basis)  ,  before  the  Atomic  Safety  and 
Licensing  Board,  in  the  matter  of  Long  Island  Lighting 
Company,  Shoreham  Nuclear  Power  Station  Unit  1,  Docket 
No.  50-322-OL-3,  April  13,  1987. 

39.  Rebuttal  Testimony  of  Gregory  C.  Minor  and  Steven  C. 
Sholly  on  behalf  of  Suffolk  County  regarding  LILCO's 
Reception  Centers  (Addressing  Testimony  of  Lewis  G. 
Hulman) ,  Docket  No.  50-322-OL-3,  May  27,  1987. 

40.  Review  of  Selected  Aspects  of  NUREG-1150,  "Reactor  Risk 
Reference  Document,"  prepared  for  the  Illinois 
Department  of  Nuclear  Safety  by  MHB  Technical 
Associates,  September  1987. 


*    Available  from  the  U.S. 
Public   Document   Room, 
Washington,  D.C. 


Nuclear  Regulatory  Commission, 
Lobby,   1717   H   Street,   N.W., 


381 


® 


NEW  ENGLAND  NUCLEAR  NEWS 
NUCLEAR  OENERATIOM  AS  A  PERCENT  OF  TOTAL  ENERGY  REQUIREMENTS 

APRIL,  1M7 

CAPACITY  FACTORS 


Connecticut  YankM 

Millston*  1 

MHIston*  2 

Millstone  3 

Vermont  Yankee 

Maine  Yankee 

Yankee 

Pilflnm 

'coastdown 

WeighlBd  Ayngt  Capacity  Factor 


Nat 

Barrala 

Year  to 

KilowatttMHira 

Oil  Saved 

Menth 

Date 

Cumuletlve 

% 

% 

% 

334.216,000 

554,300 

80.0 

92.0 

76  0 

463,479,000 

766.600 

977 

970 

684 

597,711,000 

991,200 

94.9 

81  1 

625 

463,732.000 

752,500 

547 

687 

789 

353,972.000 

587,000 

95.8 

991 

687 

-0- 

-0- 

-0- 

641 

689 

97,011,000 

160.900 

•771 

865 

70.9 

-0- 

-0- 

-0- 

•0- 

529 

58.6% 


71  1% 


67.0% 


Total  Nuclear  Generation 
Total  Energy  Requirements 
Nuclear  as  %  ot  Total 
Total  Barrets  Oil  Saved 


2,300.121.000 

8.184.000,000 

281% 

3,814,500 


TWELVE  MONTHS  ENDED  APRIL  1987: 
Nuclear  Generation: 

Nuclear  as  a  Percent  ol  Total  Energy  Requirements: 
Barrels  of  Oil  Saved:      . 


32.699.000.000  kwhs 
32  0  percent 
54.227.000  barrels 


/-■■ 


New 
England 
Nuclear 
News 


ELECTRIC  COUNCIL  OF  NEW  ENGLAND 

54  MIDDLESEX  TURNPIKE.  BEDFORD.  MA  01730 


382 


.e«-. 
'  •  -;  .  s 

JUNE  1987 
(April  Data) 

CONNECTICUT  YANKEE 

On  April  16,  the  plant  shutdown  because  of  problems  with  turbine  control  valve  #4.  After 
chemistry  holds  and  a  load  runback,  the  plant  reached  full  power  (94%)  on  April  2lst. 
The  Institute  for  Nuclear  Power  Operations  (INPO)  will  conduct  its  annual  critique  of  plant 
operations  beginning  on  June  8th. 

MAINE  YANKEE 

Maine  Yankee  shutdown  for  refueling  is  proceeding  generally  according  to  schedule  with 
startup  expected  in  early  June.  Very  small  cracks  found  in  the  disks  of  both  low  pressure 
turbine  rotors  have  necessitated  the  replacement  of  one  and  the  repair  of  the  other. 

YANKEE 

Yankee  began  its  18th  refueling  on  May  2nd.  The  last  cycle  of  the  plant  produced  more 
than  2  million  megawatthours  over  a  17  month  period  with  a  capacity  factor  of  93  percent. 

PILGRIM 

Pilgrim  remained  off-line  during  the  month. 

VERMONT  YANKEE 

On  April  4,  Vermont  Yankee  came  down  in  power  and  took  the  turbine  off-line  to  repair 
a  small  steam  leak  in  a  main  steam  drain  line.  The  plant  came  back  on-line  the  same  day 
and  operated  at  full  power  for  the  remainder  of  the  month. 

MILLSTONE  1  &  2 

Millstone  Unit  1  operated  routinely  for  the  month  of  April.  A  scheduled  refueling  outage 
will  begin  in  mid-June  and  last  for  approximately  10  weeks.  Millstone  Unit  2  operated  routine- 
ly except  for  a  trip  on  April  16  due  to  a  generator  exciter  field  circuit  breaker  opening  on 
presumed  bistable  transformer  fault  lndk:ation.  Instruments  in  place  to  monitor  the  suspect 
bistable.  The  unit  returned  to  service  after  a  20  hour  outage  on  April  ia 

MILLSTONE  3 

Millstone  Unit  3  returned  to  service  after  a  scheduled  outage.  After  startup  on  April  11, 
the  unit  tripped  on  the  next  day  while  at  10  percent  power  level  due  to  steam  generator 
low  level  when  turbine  driven  feed  pump  oscillated.  Feedwater  regulating  control  valve 
failed  to  open  on  demand  due  to  a  control  air  leak.  The  unit  returned  to  service  on  April 
14  after  being  out  for  29  hours. 


Qcne 


PuOiith»d  Dy  irt« 

Nuci««r  inionnatlon  Commtn** 

of  mt  Etsar'C  Council 
ot  New  England 


383 


^  ,.  NUCLEAR    REGULATORY   COMMISSION 

Z  REGION  I 

I  til    rsMK   AVCfaus 

•  KINO  or  roussi*.  rCNNSVLVANIA     I  MO* 


AUG  27  1986 

Docket  No.   50-293 

Boston  Edison  Company  M/C  Nuclear 
ATTN:   Mr.  James  M.  Lydon 

Chief  Operating  Officer      ^ 
800  Boylston  Street 
Boston,  Massachusetts  02199 

Gentlemen : 

Subject:   Confirmatory  Action  Letter  86-10 

This  letter  is  to  provide  further  guidance  on  the  requirements  we  expect  to  be  met 
prior  to  the  restart  of  the  Pilgrim  plant.  We  acknowledge  receipt  of  Boston 
Edison  Company's  (BECO)  letter  of  June  16,  1986,  in  response  to  CtSTfi  rmatory  Action 
Letter  (CAL)  86-10.  Your  actions  with  regard  to  the  issues  in  CAL  86-10  appear  to 
be  thorough  and  technically  sound., .My  staff  has  a  few  remaining  questions,  which 
have  been  discussed  with  your  staff  and  which  will  be  documented  in  Inspection 
Report  50-293/86-25. 

In  addition  to  the  specific  plant  hardware  issues  involved  with  CAL  86-10,  several 
other  issues  have  been  identified  that  require  resolution  prior  to  restart  of  the 
Pilgrim  plant.  Specific  technical  issues  of  concern  include:  overdue  survPil- 
lances.  malfunction  of  recirculation  motor  generator  set  field  breakers,  seismic 
Qualification  of  emerqency  diesel  generator  differential  relays,  and  completion  of 
Appendix  R  modifications.  Please  be  prepared  to  discuss  %he%e  issues  at  our  next 
management  meeting  at  the  plant  on  September  9.  1986!  V/e  would  also  like,  to  near 
at  this  meeting  the  scope  and  status  of  all  vour  Droarams  related  to  restart  of 
.Pilgrim.  These  include  (a)  the  results  of  your  six  week  action  plan  for  improve- 
ments, (b)  the  role  of  BcCO  safety  review  committees,  including  the  Program  For 
Fxrpllpnce  Task  Force,  in  assessing  readiness  for  restart,  and  (c)  the  readiness  of 
the  plant  and  corporate  staff  to  support  plant  startup,  testing,  and  operations. 

In  light  of  the  number  and  scope  of  the  outstanding  issues.  I  am  not  prepared  to 
approve  restart  of  the  Pilgrim  facility  until  vou  nrnvide  a  writtpn  rppnrt  that 
documents  BECO's  formal  assessment  of  the  readiness  for  restart  operation.  This 
assessment should include your detailed check list  for  assuring that  all  out- 
standing items  have  been  satisfactorily  resolved  and  that  plant  systems  have  been 
restored  and  prepared  for  operation.  A  formal  restart  program  and  schedule  should 
also  be  submitted  for  NRC  review  and  approval.  This  program  should  include  hold 
points  at  appropriate  stages  such  as  critical ity.  completion  of  mode  switch  test- 
ing, and  at  specific  milestones  during  ascension  to  full  power.  Authorization  to 
proceed  beyond  each  hold  point  will  be  contingent  upon  my  approval  and  will  be 
based  on  my  staff's  evaluation  of  the  operational  performance  of  the  plant.  We 
will  have  substantially  augmented  NRC  Inspection  coverage  during  this  restart 
period. 

Please  plan  to  submit  your  readiness  assessment  and  restart  program  and  schedule 
at  least  fortv-five  days  before  your  planned  startup  from  the  current  outage.  My 
decision  on  restart  will  be  based  In  part  on  our  review  of  these  documents. 


384 


Your  cooperation  is  appreciated. 


Sincerely, 


'7A>»»«**-'S 


Thomas  E.  Murley 
Regional  Administrator 

cc; 

L.  Oxsen,  Vice  President.  Nuclear  Operations 

A.  E.  Pedersen,  Station  Manager 

Paul  Levy,  Chairman,  Department  of  Public  Utilities 

Edward  R.  MacCormack,  Senior  Regulatory  Affairs  and  Program  Engineer 

Chairman,  Board  of  Selectmen 

Plymouth  Civil  Defense  Director 

The  Honorable  E.  J.  Markey 

J.  D.  Keyes 

Senator  Edward  P.  Kirby 

The  Honorable  Peter  V.  Forman 

Sharon  Pollard 

Public  Document  Room  (PDR) 

Uocal  Public  Document  Room  (LPOR) 

Nuclear  Safety  Information  Center  (NSIC) 

NRC  Resident  Inspector 

Commonwealth  of  Massachusetts  (2) 


385 


t'^r^M    i  «£GIONl 

^-'        .3'  KING  or  'auniA    'IMNSVLVANIA  1t4M 

•...♦ 

APR  0  £  1997 
Cornet  No.  50-293 

Boston  Edison  Compiny  M/C  Nuclear 
ATTN:   M-.  Ralph  Bird 

Senior  Vice  President  -  Nuclear 
&Z0   3oyl stor  Street 
=c;-.cn.  Kasjacr.. setts  CZ193 

Ge-*. 'em«n: 

Subject       Systematic  Assessment  of  Licensee  Performtnct  (  SALP)  Reoort 
No.    SO-293/86-99 

"-6  R»;-or,  I  SAl?  esarc  las  reviewed  and  evaluated  the  ptrfor««itc«  of  actfv- 
T.-es  at  tn?  Silgr-m  Nuclear  Power  Station  for  the  period  Novtmbtr  1,  :9£5 
tr,rcJ9^  January  31,  1987.  The  results  are  presented  1r  ih«  enclostd  re?:'rV 
A  -i9f'<;  tc  o-.scjss  *.hi$  assessment  will  &»  scheduled  -for  4  •utually  ictep:- 
iz' i  Ci.e  T-e  -reting  .•::  ss  leld  en  or  near  the  site  so  that  appr<:p--'i-e 
i«-  -.'  -croc'jte  r-e-acerent  arc  piant  c'ficlals  ccn  discvss  w1  ih  ^%  t-e 
:-.-?-:t.-i  a-d  ■.rc-.-esses  r.oted.  It  is  ojr  <r^tnl  that  this  iraetlng  fet  ecsrSinec 
«■•.'■     -.'e    per-oc-c    -.cra9eT:ent    meeting    to    review    Icorcv  enen    progpia    status' 

'-t    SALP    Boa'S     -centified    significant    recur-lng    progra  n    veakntsses     *-     i:-e 

•■--rt-onal  areas.  Irprovewents,  such  as  ir,  tr,e  are*  of  ene'sency  preparediess. 
-e-s    i^sc   n?:sc       However,    the   SALP    Boarc    *ound    the    rare    of    such    charte  '.aJ 

slow  iurirg  nost  -'  the  assessment  pencd. 

We  recognize  tfat  the  Boston  Edison  Company  (BECo)  has  B;adt  significant  scaf'- 
•-;  a-c  '■'-ir^i.rt  conritinents  to  inprcve  per'ormance  at  t^:e  Pllgrln  rtaticr  and 
»e  se'iieve  they  a'e  beginning  to  have  a  positive  iaipact.  Aj  you  art  aware,  t.-e 
S^C  ■'.  ><o»ing  for  progress  In  correcting  the  previously  1dtnt1f1«t  lor:'te  — 
:-ei'?-i  at  :ie  P-lgrip  Station  prior  tp  c'ani  -estart.  particular'/  if-' --:■.: 
■'.'T-zi'    areas  -'tn  a  Category  3  rating. 

In  ;-e;;-«t:or  fpr  the  SAL?  netting,  please  oc  prtparttf  t.9  discuss  ysar  tvalua- 
t-cn  cr  our  asstssmtnt  and  tht  status  of  ycur  ptrfermancf  ImprowtBtrt  prc;-c-i 
Ary  ton-rents  you  way  have  regarding  our  resort  may  be  discuistd  at  f.t  mssf-:. 
Acc-fi-all/^  you  may  provide  written  co.r-ents  witnin  20  days  after  tht  neet- 
'■''■<3  follotiMf  our  iiittting  and  rtctipt  of  your  wrltttn  rtsponst,  tht  tnclosea 
-eport,  your  rtsponst.  and  a  summary  of  our  findings  ar d  olanntd  actio-*  wi"' 
te  ;"icea  in  tht  NkC  Public  document  Room. 


386 


63 


•ABLE   4 

•NFQRCEMEN-   SUMMARY   (11/:: '85   -  01/31/67) 

PILGRIM  NUCLEAR   POWER   STATION 

Sj-se"-  ane  Sevfity  Ltve'    o'  V'cltnons 


Seventy  Level  I 

Seventy  Leve^  II 

Severity  L%ve'  HI 

Seventy   Leve"  IV 

Sevei-ity   Leve'  V 
2s.  ■ ati on 


.  • : '  o 1 1 0 n s  7s     -u^ct'ca"    Area 


0 
0 
1 
21 
6 
1 

IT 


•C^o 


>«ve''t.    Le^e    s 
'iT       iV        V      .".'ev     TcT«l 


'■'  i".  Ore'sv  :-s 
■I'.-z'  zz-  zi'    C:--.-:'s 
"i   --.e-a-ce 
S.'.e- ■ 'ance 

E-c-ge-cy   --e:i-?c-ess 
:'r.---.y  Se-'ec.s<-cs 

Cj".agt  M«n»ctfrer,t  jno 
"ic-fiCiilo^  if.ivities 

L-censing  Activities 

'c'*'ng  anc  C ja 1 i f icati on 
E"  'eC'.'  veness 

-::.-c':fc   :'   :.r-y 


1 

3 

1 

5  3 


0 

c 


ca'.    S, :::--. 


a 


387 


6£ 


'ABA  t   iZo'-r.^-.^eC) 


Sumrn* ry 


.-spection 

JTese-".  Severity  Punctionil 

s^nsf '.eve' Arta  V<o1it1on ^ 

£S-2i  V  Surveillance  Instrumtnt  chtnntl   tt$t$ 

wert  not    bting   performed 
monthly   for  tht  r»tctor 
building   vtnt  and  stack  waste 
9<t  Mnit.ors. 

=  :-:*  V  Secj"t>  P«nure  to  perform  a 

Se'e;.e'--s  oroper  jtarcn  of  a  package 

trcught  1  nto  the  protected 
area. 

if-::  ;•  -'ir'.  Post  tri5    review  86-01   arc 

Zii'ii^c".  86-02  U:  <.ec  recalred 

recorde'  .:*«i-t$.      Inadeouat? 
cortrol   - 3om    let  entries  c 
O'sa&ied  ur.r.w.'.c-.ators. 

i-:-:i  :::  ne;-o1o;-Cc"  *  waste  s+iioTe-t  of  solid 

If'.'-z'i  metall'^c    oiices   on  rrcn- 

lompactec    trash   lacked 
re;uirea   jtrong  packaglftg  i-z 
Quality  control   seasures 

::-;£  :,  Sj've-llirce  Replaceme-nt  squib  charges 

were   instaned   '.n   the    star.:;, 
liquid  ccTtrol    syster   frc-    a 
3atch  tCet  hatf  not  be«n  les.e: 
Curing  a  manual    Initiation    c - 
tne  Standby  Liquid  Ccntrol 
System. 

c:-::  IV  Ra::olcg'cal  Radiatlor    surveys  of  paciaceo 

Coitro's  irradiated  reactor  components 

were  not   cocu'cnted  on 
appropriate  radiation    survey 
forms  anc    macs. 

ci-'.l  ".,  iji.-o-:e   o'  Quality  c  ontrcl    reasu-es  we -e 

!.=  ■■-...  -.at  tc«e-    -n  trarsfe"-'re 

rac"c*ct"  ■'•  waste    sh:pmerts 


388 


C3 


^ABlE   i    (Cont^njed) 


Sun.Tiiry 


inspecii on 

Report  Severity  Functional 

\.-:e' Level A^ea Violation 

S:-14  :v  Assurance  0^  Prtvlously  Idtntlfled 

Quall'.y  intfliquaclis    Involving 

survtillanct   ttitlng   of  t-e 
high  prtsiurt  coolant 
Injtciion   systtm  were   not 
corrtctea   'or    six  ncnths 

if-".-:  V  S j've- ' ' a'ce  Failure  to  sroperly  cont-cl 

•i«4$urinc    and   tejt  equ'.c-art 

:5-Zl  ;*'  Su've-'^once  Eatt«ry  'ater   "  saa  C"sc'is-;e 

Test  proceCjrs   was  not 
jpaatec  t.o  -e'"ect  sj-stetr 
alteratlo-^s  a-c   rtstorat'sns 

:•:-;:  '. .  ^ssurir-e    if  Failure   a  nc   '•'al  f  unct"  on 

Cj«"':v  fleoo't  was   nrt  completei 

by  engineer- -g  ptrsoinei    a'te* 
tney   id«ntif-.ed  deficient 
station  *ire    tar»lers. 

li-Z'-  Su-ve'i"ance  SurveiHa  ice    tests  we^e 

performec    wit*o^t   inreperce--. 
veri  f  icat 'on    of  systei*   res:.:-; 
ana   system  restoratic*.. 

iz-ll  Oevation  F--e   '"-otecf:-  Failure  to  conply  ^it^   tre 

coiT.Ti  traert  to   conduct 
quarterly    fire  brIgaCe  ar-'': 
for  all    '1re   brigade   me-oe's. 

i:-j-  IV  Secur-ty  Improper  paci(.a9e  se«r-cn  ana 

Safeguards  inadequate  follow  up. 

ii'li  iv  Pire  Protection  Fire  brigade  members    riad  -^t 

received  the   required 
training. 

i-.-2-.  '. :  t^'re   '':-.e:fr-  -'r»  watc-.es    'ailed   '.'-j   ;e''':*" 

the  required  hourly  ;atrc'    o' 
the  motor   generator  set  -::- 


389 


66 


C  .  S  uomi  ry 

Inspection 

Serct 


Stve'i ty 
.evel 


"AqlE  i    (Contlnjtd) 


Tunctionil 

Arjj 


VioUtlon 


£6-37 
86-37 


IV 

IV 

IV 


Pire    Protection 
^^odi  ^ic«f.ons 

-■'e  Prcterfcn 


In*dtquatt  fire  brigade  Crii: 

Sif«ty-r«1»t«d  BOdl'lCJiions 
were   not    perf or««d   1 n 
tccordtrcc  with  •pplicablc 
design  rcqulriments. 

AdcQuate    procedures  and 
Cnwings    hid    not  been 
estiblisned   •^or  the   stiticn 
*ire  wet  sr  s.ifStea. 


-■--i.i 


•-C1 


87-03 


'-33 


:v 


IV 


IV 


IV 


IV 


Oiogicc' 

Fi^.ure   tc   1-;    ement   a 

rolS 

radioloQ ical    co'trol    orocec. 

for  c'>ec«.inc    ve-.icle'S   1ea>'- 

the   site  . 

-ve  I  '  laice 


's'. -tenance 


P'-e  Protection 


Radiological 
Cc-t'o I s 


i'S'-'a'ce 


Fai.ure  to  ad^•re  tc    tie 
proceOwrtJ  gnveming 
survei  1  ";.anc€    te;t1nc   of  t-e 
Post  Acc'der-.  Sampling 
Syster  ( -^ASS  )   system  . 

Lack  cf  ;)rocedure  guidance   c- 
raaintena-ice  cf  th«  neat 
tracing   ciortrol    drcjlt   ri'j^i 
for  the  f'ASS    system. 

Failure  to  take  required 
action  for  Inoperable  fire 
protecf.on  eculpment. 

Failure  to  control   a  master 
key  to  a*  1   lc:k.ea  nl;h 
'•adiation  areas. 

Fai''u-e   and  "alfuncfon 
Sesc-t  r. 3t  cc-ipleteC   afte- 
a  sa'et. -'elated  t-s   trar,-?- 

cic  rot    r>ccur   during    a 
■survei  ■'' ence    test. 


390 


67 


'ABlE  i  (Continued) 


S  jmiiupy 


inspection 

neoo't  Severity  Punctionil 

s.-:e- '.eve^ Area Violation 

i'-Qi  IV  Surveillince  A  survcHlanc*  test  on  Staniiiy 

Gas  Tre»UMnt  Systtm  failed  tc 
meet  tht  Inttrt  of   the  Tech 
Socc   rcqulrttitnts. 

£7-Ci  IV  jurveillance  Failure  to  calibrate  measur'-g 

and  test  cqufsrent. 

t"-:-  v'  *!od"  f  ication  Perforr>ing   pcst-aodi  f  Icatlc" 

test  or.  the   refuel   bridge 
w^thou^  a;;-rved  procedure 
changes. 

£"-;i  'A  Surveillance  Maste*-    test   r':;ram   proceCL'ei 

00  not    «cec. ---.ely  acdress 
su'vei  "  I*'' :      test  ard  pest 
modi f leaf         test  programs. 


391 


UNITED  state: 
-"    >  /      '■     ^-  r..C;-=aF  REGULATOR  y  COWV!S.S'0' 

i    J   ^   ■    --■  .  RECn.   : 


i  ~--i 

MAY  2  0  1986  RECEl  V  C.L 


Docket  No.   50-293 


Boston  Edison  Company  M/C  Nuclear 
ATTN:  Mr.  William  0.  Harrington 

Senior  Vice  President,  Nuclear 
800  Soylston  Street  i 

Boston,  Massachusetts  02199 

Gentlemen: 

Subject:  Systematic  Assessment  of  Licensee  Performance  (SALP) 
Report  No.  50-293/85-99 

This  letter  refers  to  the  Systematic  Assessment  of  Licensee  Performance  (SALP) 
of  the  Pilgrim  Nuclear  Power  Station  for  the  period  of  October  1,  1984  through 
October  31,  1985,  Initially  forwarded  to  you  by  our  February  18,  1986  letter 
(Enclosure  1).   This  SALP  evaluation  was  discussed  with  you  and  your  staff  at 
a  meeting  held  in  Plymouth,  Massachusetts  on  March  5,  1986  (see  Enclosure  2  for 
attendees).  We  have  reviewed  your  March  26,  1986  written  comments  (Enclosure  3) 
and  herewith  transmit  the  final  report  (Enclosure  4). 

Overall,  your  performance  in  the  operation  of  the  facility  was  found  acceptable 
although  some  areas  were  only  minimally  acceptable. 

As  projected  in  our  letter  of  February  18,  1986,  a  special  In-depth  team  in- 
spection was  conducted  from  February  18  to  March  7,  1986  (Inspection  Report 
No.  50-293/86-06)  to  determine  the  underlying  reasons  for  the  poor  performance 
discussed  above   The  team  found  that  improvements  were  inhibited  by  (1)  incom- 
plete staffing,  in  particular  operators  and  key  mid-level  supervisory  personnel, 
(2)  a  prevailing  view  In  the  organization  that  the  improvements  made  to  date 
have  corrected  the  problems,  (3)  reluctance,  by  management,  to  acknowledge  some 
oroblems  identified  by  the  NRC,  and  (4)  dependence  on  third  parties  to  identify 
problems  rather  than  Implementing  an  effective  program  for  self-identification 
of  weaknesses.  We  believe  these  findings  confirmed  the  SALP  Board  conclusions. 

We  acknowledge  your  discussion  of  program  and  staffing  improvements  in  plant 
operations,  radiological  controls  and  emergency  preparedness.  However,  we 
believe  that  tht  success  of  your  programs  depends  upon  resolution  of  the  four 
principal  factors  Inhibiting  Improvement  noted  above  which,  in  turn,  depends 
heavily  on  MingMwnt  attitudes  and  aggressive  followup.  In  this  regard  we 
request  that  you  be  prepared  to  discuss  the  scope,  content  and  schedule  of  each 
improvement  program  at  a  management  meeting  scheduled  for  1:00  p.m.  on  June  12. 
1986  at  the  NRC  Region  I  Office. 


392 


TA5.;  i. 
en-:':e--es'  Su^^'<>ry  (:c'i/84  -  io/3i.-g;) 

PILSRIM  NUCllAR  power  STATION 

FUNCTIONAL  AREAS 

A.  Pljnt  Operjtions 

B.  Rafiiologicil   Controls 
C         Kj-rterarce  L  ^::- •' ■  ca-.ioi-s 

D,  Survei  ■!  "larce 

E.  Efrergency  Preparesress 
F  Security  I,  Safeo-arcs 
G-  Refueling  &  Outage  ^'ar.agement 
H  Licensing   Acti  vi ties 

":-.a"s  6>    U.i'-:,    .e.f'  C  :  2     17       5  2  27 


Seve 

-■ty 

Level 

_$ 

I 

II 

III 

IV 

y 

DEV 

Tota' 

- 

- 

- 

4 

2 

6 

- 

- 

1 

1 

1 

5 

- 

- 

- 

1 

- 

• 

- 

- 

- 

9 

2 

:z 

- 

-' 

- 

2 

- 

z 

- 

- 

1 

- 

- 

1 

- 

- 

- 

- 

- 

0 

- 

- 

- 

- 

- 

- 

0 

393 


Injp. 

Ipso. 

SevB'-ly 

Func-.iorjl 

No. 

D<tt 
n/1-11/85 

Lev»l 

krtt 

84-36 

IV 

P1«nt 

Op«rit1ons 

IV 

PUnt 
Optrjtions 

'AS.-:  5 

PILGRIM  NUCLEAR  POWER  STATION 


V1o1«t1on 

F»11urt  to  conduct  in  adequate 
shift  turnover  for  control  room 
perjonnel  auring  refueling 

Failure  to  continuously  momto'" 
source  range  mon-tl'S  dj'-ng 
refuel 1ng 

84-39     11/21-  IV     Surveillance   Failure  to  promptly  Identify 

12/31/84  conditions  adverse  to  quality 

(I.e.  failure  to  initiate  Fa'lu'e 
and  Malfunction  Reports) 

84-41     12/10-13/84      IV    Emergency     Failure  to  disemlnate  emergency 

Preparedness   planning  information 

IV    E-?':j-:y     railurt  to  update  the  emerge'cy 
-'e:2-i:-iss   r's'  I'Z   pr;:e3»-ei 

84-44     12/1S-1S/64      :::     Radiological   Failure  to  follow  radiation  work 

Contro'S      permit  Instructions  and  failure 
to  establish  a  procedure  for  a 
remote  reading  teledosimetry 
system 

65-Cl     1/1-31/E5         V     Plant         Failu'-e  to  maintain  control  room 

C;er4-.icrs     staffing  at  levels  required  by 
10  CFR  S0.S4 

IV    Surveillance   Failure  to  test  the  containTiert 
cooling  subsysten  Immtdlately 
when  the  low  pressure  coolant 
Injection  system  was  inoperable 

65-03    Z/l'SS-         IV    S-'veil lance   Failure  to  conduct  surveillance 
3/4'£5  tests  for  the  reactor  protectim 

system  (six  txaaples) 

IV    Surveillance   Failure  to  conduct  rod  block 

surveillance  Utts  (five  examples) 


394 


-3-i 


Inip.     I'-s;  Seve'ity  Functional 

No.      D«te  Leve'      A-ea       V'ci*-.ion 

IV     P1«nt  Ftllurt  to  proilptly  correct  cc-" 

Operjtloni     dltlonj  *dver$»  to  gutlUy  (i.e. 
fillurt  to  t*k.«  timely  «ctlon 
on  Oujllty  Aiiurtnce  survt1ll»nce 
f indlngj) 

V  Surveillance   Fi11ur«  to  UM  M»  MSt  current 

revision  of  ^  MiMtei^  ^tnce  test 
procedure     ^!- 

V  Surveillance   Failure  to  calibrate  test  eouip- 

■tnt  within  the  calibrated  penod 

85-06     3'5'E:-  V     Plant         Failure  to  maintain  an  uncall- 

i/l/ll  Operations     brated  local  power  range  ironltor 

In  a  bypassed  state 

IV    Maintenance    Failure  to  conduct  a  dioctyl 

phthalate  test  of  HEPA  filters 
following  naintcnancc  on  the 
standby  gas  treatment  system 

85-13     5/2C-24  '£5        V    Radiological   Failure  to  have  the  Operations 

Cc-t'ols      Rev.e*  Con-mittee  (3RI)  review 
tw:  rai'c^:g-c4'  procei-'es  t-t 
failure  to  control  worii  in  the 
fuel  pool  with  a  maintenance 
request 

Cevietion     Radiological   Failure  to  conduct  an  adequate 
Controls      review  of  systems  that  could 
generate  *n  uncontrolled,  un- 
monitored  radioactive  effluent 
release,  as  recominended  in  IE 
Bulletin  80-10 

85-17     6'13/85-         IV     Surveillance   Failure  to  conduct  a  surveillance 
7/15/65  surveillance  test  of  the  2S0  V 

battery  system  required  by  the 
technical  specification  and  to 
follow  station  procedures  for 
additional  battery  tests 

IV    Radiological   Failure  to  specify  high  radiation 
Controls      area  surveillance  freoje-cies 
on  radiation  ••rd  pennits 


395 


•-S-3 


Deviation    Surveillince   F«11ure  to  conduct  inse'-vice 

ttjts  as  specified  in  an  NRC 
Submittal 

85-20    7':6/S5-        IV    SyveiT  lance   FaMure  to  maintain  the  f-o 
8/19/85  level  setting  far  the  "B"  and 

"C"  Min  sttaa  Itne  high  radi- 
ation monitors  within  technical 
specification  limits 

85-21     7'16/£5-        IV    Sur^eniance   Failure  to  maintain  secondary 
7/30/S5  containment 

IV    Su'veil'ance   Failure  to  test  alternate  safety 
system  when  an  emergency  diesel 
generator  was  found  to  be 
Inoperable 

IV  Surveillance  Failure  to  initiate  Failure  and 
Kalfunctlon  Reports  as  required 
by  station  procedures 

85-24     8/6-e'e5        III     Security      Failure  to  maintain  ar  adeauate 

v'tii  area  barne- 

85-26     ;  Z:  £5-         IV     P'ant         Failure  to  properly  authorize 
9  2i/£5  Operations    excessive  licensed  operator 

over-.ime  as  required  by  station 
procedures  (thirty-five  instances) 

£:-27    9 '16/85-   Deviation     Radiological   Failure  to  install  a  protective 
5  ;'  c:  C;--.'c"s       conduit 


396 


;  UMTED  STATES 

■-  NUCLEAR  REGULATORY  COMMISSION 

I  nCGION  I 

/  U1  »*KK   AVtH\Jt 

KIMC  O'  »«USSIA    rtNNSVLVANIA  IMM 

Ooc^.t  NO.  50-293  j^^  ^5,3gc  '^  '  ^-  ^  ■  :   ,. 

Boston  Edison  Company  M/C  Nucliar 

ATTN:   Mr.  William  0.  Harrington 

Senior  Vice  President,  Nuclear 
800  Boylston  Street  ''^''  C< 

Boston,  Massachusetts   02199 

Gentlemen: 

SuBject;  Systematic  Assessment  of  Licensee  Performance  (SALP)  Report  No  50-293. 
84-34  and  Your  Reply  Letter  BECo  85-031  Dated  FeOruary  12,  1985 

Thank  you  for  your  reply  to  SALP  Report  No.  50-293/84-34.   In  your  lette'  you  s-e- 
sented  additional  information  concerning  assessments  and  requested  we  recofHioe- 
some  of  the  assessments  to  Better  account  for  the  assessment  period's  extraora- narv 
circumstances  (i.e.,  the  extended  outage  for  piping  replacement). 

Based  on  our  discussions  with  you  at  the  January  23,  1985  management  meeting  and 
the  information  presented  in  your  reply  letter,  the  SALP  Board  founa  it  appropriate 
to  revise  the  declining  trend  of  the  Category  2  rating  for  fire  protection/house- 
keeping to  a  Category  2  rating  with  a  consistent  trend.  We  feel  this  is  appropria*. 
as  we  may  not  have  properly  accounted  for  the  extended  outage  m  our  evaluation 
for  trend.   However,  we  continue  to  feel  that  the  extent  of  contamination  tnat 
existed  throughout  the  plant  was  inconsistent  with  a  Category  l  rating.  The  en- 
closed SALP  Report  has  been  supplemented  to  reflect  this  change.   The  SAL?  Boara 
also  found  that  the  other  ratings  should  remain  unchanged. 

With  regard  to  the  current  status  of  your  operations,  we  acknowledge  the  improving 
trend  of  your  performance  in  the  plant  operations  and  maintenance  areas  ana  en- 
courage you  to  continue  your  efforts  in  these  areas.   Further,  we  note  me  prog'ess 
Being  made  in  implementing  your  recently  established  Radiological  Improvement  Pro- 
gram and  encourage  your  efforts  to  decontaminate  the  plant,  to  reduce  plant  --aai- 
ation  levels,  to  enhance  oversight  of  the  radiation  protection  program,  and  to 
establish  support  for  the  program  by  plant  personnel. 

Your  cooperation  with  us  ii  appreciated. 

Sincerely, 


Thoatas  E.  Hurley^  ^ 
Regional  Adainistrator 


397 


38 


TABLE  2 
VIOLATION  SUMWARY  (7/1/83  -  9/30/84) 
PILGRIM  NUCLEAR  POWER  STATION 


A.   Number  and  SevtrHy  Lev«1  of  Violations 


Severity  Level  I 

Severity  Level  II 

Seventy  Level  III 

Severity  Level  IV 

Severity  Level  V 
Deviation 


ToUl 


0 

0 

1 
18 

6 
_1 

26" 


B.   Violations  Vs.  Functional  Area 


Functional  Areas 


Severity  Level 
I   II   III   IV   V   OEV 


A. 

Plant  Operations 

2 

5 

B. 

Radiological  Controls* 

1 

7 

1    1 

C. 

Maintenance 

2 

0. 

Surveillance 

1 

E. 

Fire  Protection  and  Housekeeping 

F. 

Emergency  Preparedness 

G. 

Security  and  Safeguards 

6 

H. 

Refuel inq  and  Outage  Management 

I. 

Licensing  Activities 

Totals* 


18 


'Totals  do  not  include  three  apparent  violations  and  one  apparent  deviation  in 
the  area  of  radiological  controls  that  were  identified  during  inspection  84-25. 
NRC  enforcement  action  was  under  review  at  the  end  of  the  assessment  period. 


398 


39 


C.        SumiTiary 

Insoection  Insptction  Stwerity 

Report  No.  Dat«  Level 


83-19 


83-20 
83-21 


83-23 


83-24 


84-03 


84-04 


84-06 


8/15-10/3/83 


8/8-12/83 


8/22-24/83 


1/20-27/84 


2/7-3/12/84 


2/13-17/84 


IV 


i:/4-ll/7/83     IV 


IV 


11/8-12/31/83    IV 


III 


IV 


IV 


functional 
Area 


Violation 

Failure  to  review  ana  se- 
date special  orcers 

Failure  to  vent  3iD-?5  '--- 
the  hign  point  in  i,-.e  ::-» 
spray  system 

Failure  lo  follow  a  Rao'- 
ation  Work  Permit 

Failure  to  schedule 'exte— 
nal  audits 

Failure  to  document  defi- 
ciencies in  deficiency 
reports 

Failure  to  conduct  an  in- 
service  test  on  a  hign 

pressure  coolant  inject'in 
(HPCI)  valve 

Failure  to  review  a  proce- 
dure for  procuring  safety- 
related  items. 

Failure  to  record  reactor 
vessel  cool  down  rate 

Failure  to  label  a  contai-er 
of  licensed  material,  use 
extremity  dosimetry,  anc 
instruct  workers  on  radi- 
ation levels 

Failure  to  maintain  a  pro- 
cedure for  the  proper 
operation  of  the  contain- 
Mnt  atmospheric  dilution 
system 

Failure  tc  follow  a  radi- 
ation work  permit 


399 


40 


Inspection 
Beport  No. 

84-11 


84-13 


Inspection 

Date 

4/23-27/84 


4/24-27/84 


84-14 


5/9-11/84 


84-22 


7/16-20/84 


Severity 

Level 

IV 


IV 


functional 
Area 


IV 


OEV 

IV 

IV 
IV 

IV 
IV 
IV 
IV 


B 
B 

G 
G 
G 
G 


Violat^'on 

Failure  to  maintain  a  :rc- 
cedure  for  control 'ing 
welding  slag 

Failure  to  property  -o.,-ew 
and  approve  cont- acto-  :-t- 
cedures  involv-ng  trans^c- 
tation  of  radioacfve 
materials 

Failure  to  comply  wifi  fe 
requirements  of  a  Cerf *•- 
cate  of  Compliance  for  a 
transport  package 

Failure  to  properly  docume"': 
a  quality  assurance  program 
for  transport  packages 

Failure  to  fulfill  a  t-ans- 
portation  training  comm-t- 
mtnt 

Failure  to  instruct  wor<e-s 
on  the  presence  of  raa:c- 
active  materials 

Failure  to  survey  '•adiation 
hazards 

Failure  to  implement  pro- 
cedures consistent  witn 
10  CFR  20 

Failure  to  control  a 
security  key  card 

Failure  to  maintain  pnoto 
ID  badges 

Failure  to  respond  to  two 
vital  area  alarms 

Failure  to  maintain  ore 
guard  radio  and  one  of'site 
communications  net  ooe'ao'e 


400 


41 


Insoection 
Report  No. 

Inspection 
Date 

Severity 

Level 

Functional 
Area 

Violation 

IV 

G 

Failure  to  maintain  e"i:- 
tive  compensatory  measu'-es. 

IV 

G 

Failure  to  maintain  elec- 
tive compensatory  measj-es. 

84-25 

8/6-10/84 

• 

a 

Failure  to  per'orm  -ac-af: 
surveys 

* 

B 

Failure  to  instruct  »«o-<e's 
on  radiation  hazaros 

». 

B 

Failure  to  properly  approve 
procedures 

« 

B 

Failure  to  implement  recom- 

mendations  in  Regulatory 
Guide  8.8 


84-26 


8/28-10/8/84 


Failure  to  properly  approve 
QA  program  related  proce- 
dures 


■Apparent  violations  and  dtviations.  Enforceffltnt  action  was  under  review  at  t.ie 
end  of  tnc  asscssmnt  period. 


401 


.<■•■' '"-^ 


NUCLEAR   REGULATORY  COMMISSION 
HtCION  I 


w 


*a-    sc 


KING  O'   VauSSi*     PVNNftV(.vAf«l*     i«40« 


i£?  1  i  ?Sfi3 


.r  J 


-:■:•.:■  Izi^'   -;":3->   **  !  v.:  ?a- 
i-'s      «-     *-''-a-  Z     -a'---:-.:'- 

5?-   :'    .:?   -'es"Ce-t.    N-r'ea- 
;■-    :-^-.  --^    S'.  ""^^t 
E;3-.:-     "ciSir-.ie-.-.:-     ::irr 


RECEIVED 


-i"-   ^'5'  W.  D.  H. 

i.i.i:'     ii'i"-".:  issEi!*'Es"  :-  -::en5EE  ^e^tcrmance  (Si.=  ) 

"-f  s^I  ^ec";'   I   Si--   Eca*:  cc":,;tec  a   •■evie*  on  August  25.    15E2,    a':   s.a   . 
:-T  :9-':'-a"ce  :'  a:-.'v-,-es   assoc^a-ec  w^ti  trie  Oilg-im  N^c'ea'  -:«€'   5:  =  : 
*■?  -9s-"ts   :•'   t"-s   assess-e't   a'e  Ccc^me-tec   in   tne  enc'csec   i^^-   5:o'C   -e: 
i  -sef;  "as  res'   sc-ec-'«c   *3'  Secte'-:e'  21.    19:;,   at  E'a-'t'se.   "i     :z 
ziz.ii  :-■%  asjsss^e'". 

-•-  :"»  ■'ii'.--^.   yc.   snc-';  De   :'e:a'ec  to   2'scjss  our  asses5ie"t  a'z  /C 
:'a-:   ;:   ■-:-:.«   :e'-c"^a':e       i"/    ri~"ents  yCw  may   nave   'e;3'C-'c   :.-   '?::- 
*:..   :e  :-s:.;se:  at   f»  "leefc.      Acc  fona' ^y ,   you  may   cov'ce  x-'tte"   ::  — 
'"■ —  11  Coj  s  a-'ter  f^e  Tsefng 

■:  :-'■:  :.-  lesfc  a-z  'ece':t  o*  you"-  resoo'se.  tie  e^z'ziec  '?:r't.  ,:, 
'?;::';9.  a't  i  s-mTa'>  ;•  c-'  ••nr^rgs  arc  D^annec  arfons  ••■"''  :e  z' iziz  - 
-"5  ■'■'1  -.:"■;   Icr.-e-t   ncor. 


'at  ■ : 


s  ari's: • ats:. 


S'n;e'e' 


y . 


a'-ostecK.i 


an.  j-'e:t3' 


Division  o'  Project  anc 
Resiaent  P'ograirs 


:3-'s   As  Statec 


A.    V     M;,..j,^   Ma-,age'.   Nut'ea'  Doe^ations  Suooont 

-       -       *'at-lS.     Stifcn    "o-ags-- 


402 


3S 


'AS.i  4 


SunOS'   a";  Seve'^'ty  Ueve^  c*  V'c'at'ofs 


Seve'-^y  Leve"  I 

0 

Seve-^ty  level  II 

0 

Seve-Uy  Level  III 

1 

Seve-ity  Level  IV 

9 

Seve-ity  Level  V 

20 

Dev-ations 

3 

Tota"  Violations 

30 

Vc'at'3'^s  Vs.  "un;t'onal 

Area 

'otal  Oeviat'ons  3 


Seve-'ty  Leve's 


^jnc 

'::na. 

AREAS 

I 

II 

T  »  • 

:v 

V 

DEV 

. 

5 -a-. 

Ooe-a-. 

•ons 

4 

8 

Rac-o' 

loq-ical 

Cont-o''s 

1 

- 

' 

2 

Ma-'-.i 

!-ance 

1 
* 

• 

i 

Su've 

•" lance 

5 

c.-e  1 

'-otect 

lon/Mousetieeoiic 

3 

'_ 

6 

E'^e'-aency  P^i 

Boa-eflness 

■7 

5e:u'' 

'ty  anC 

Safeguards 

1 

3 

2 

Q 

Re^ue' 

'-nc  _  __ 

C 

.•sensing  Ac 

tivitle$ 

Totals 


1 


20 


Total  Violations  =  30 
Total  Deviations  *  3 


403 


'AS_£  i   (Corf "uei) 


'SDe:for         inspection  Reoulre- 

-^ °iH SuB:e:t        ments     Seve- 


2-"-5  June  It    -  BiOCH'ng  ocen  t    f re        T.S.        V 

August  I      aoc-   w-itnout  proper 
control s 

Failure  to  evaluate    T.S.      v 

fire  loading  prior 

to  moving  combustibles 

into  safety  related 

area 

Failure  to  trinslate  10CFR50     V 
oesign  bases  into     App.  B 
drawings 

Failure  to  perform    10CFR50.59  V 
an  aaequate  safety 
evaluation  prior  to 
Changing  a  station 
valve  lineup  procedure 

Failure  to  maintain    T.S.      V 
a  fire  door  position 
continuously  annunciated 

Failure  to  perform    Fire      D 
daily  cneciks  of  non-   Protection 
alarmed  fire  doors     Review 
as  committed  to  tht 
NRC 

"'  '^  August  2  -     Failure  to  mane  a     T.S.      IV 

prompt  notification 

Failure  to  maiie  a      10CFR50    V 
50.72  notification 

Failure  to  perform  a   T.S.      IV 
Icaii  rate  test  required 
by  the  LCO  for  an 
inoperable  Vacuum  Breaker 
Alarm  System 


404 


'A=.E  t   (Zz' 


'jec 


Sjmmary 

I'lsoec^'  on 


.psoecfon 

Date 
SeD'-emoe"-  7 
Oc-.ooer  18 


Sj: 


ra"  '  jre  tc  'ev  se 
ccceaj'es  'or  -ac^c- 
acf  i/e  C  scna'-ges  as 

comiT-ttec  to  tne  NRC 


Recu-'e- 

me"*.  s 

.•  ce'-see 

Res:c' se 

V-c'a-.-on 
g-.-c-f 


Sev  9" 


32-29 


N/^C) 


0:-.obe'  19_- 
NovernDf  15 


January  31, 
1983 


January  25_ 
rearuary  28 


Imcooe'  eouipment 
tagging 

Failure  to  p'-ooe-ly 
se*.  a  main  steam 
safety  valve 

Fai'ure  to  cooe'-ly 
confol  CistnDution 
of  tne  Q-List 

Fai'iu'e  to  use  proper 
methoas  of  access 
contro I 


1QC=R5: 
App,  B 


Secy  ty 
Plan 


Failure  to  prevent      Security 
unautr.onzed  entry  into  Plan 
vital  area  or  followup 
on  a  security  Oeficiency 

Safeguards  information   lCCFn.'3-4 
not  properly  controlled 
resulting  in  a  loss  of 
copy  of  tne  site  pnysical 
Security  Plan 


Failure  to  pe-forw 
cnemistry  samples 


,S. 


Failure  to  assure  tnat   lOCFRBO 
training  certification    App.  B 
forms  were  completed 
prior  to  watcn  assignment 


Failure  to  properly 
control  nign  pressure 
gas  cylinoers 


T.S. 


:v 


ZC;- 


405 


42 


~AB.E   4   I  Zor'.'r.ueC) 


No 


83-08 


Irsoection 
Cate 

March  22- 

Acnl  13 


May  9  ■ 
May  13 


Aor-l  4 
May  3 


(2) 


April  19  - 
May  23 


Sub:ec-. 


Reoui  rfe- 

merts 


Seve- 


A-sa 


►  a^ lure  to  imole-     T .  S .        V 

ment  a  s'.atior  oro- 

cecure  for  msoection 

ana  clearing  of  me 

S3GT  System  inlet 

plenum 

Failure  to  conduct    T.S.        V 

an  audit  of  the 

Radiolog'cal  Envi'Dn- 

mental  Monitoring 

P'ogram  report  when 

requi red 

Accepting,  in  receipt  lOC^RSO      V 
inspection,  material   App.  B 
not  in  conformance 
with  the  P.O.  Require- 
ments 

Failure  to  maintain   10CFR50      IV 
the  0-List  App.B 

Failure  to  update  the  lOCrRSC. 71(e)  V 
FSAR 

Failure  to  perform    lEB  79-09     D 
preventive  mainten-   Commitment 
ance  as  committed 
to  the  NRC 

Safeauarcs  information  10CFR73.21   IV 
not  properly  controlled 

Security  access  card    Security   IV 
key  not  properly  con-   Plan 
trol led 


406 


X^fj 


UNITED  STATES 

NUCLEAR  REGULATOSY  COMMISSION 

REGION  I 

631  PARK   AVENUE 

KING  O' 'Russia  pemnsylvasia  imm 

Ooci>.«t  No.  50-293 

Boston  Edison  Company  M/C  Nuclear 
ATTN:   Mr.  William  D.  Haf'ngton 

Senior  Vice  Presiflent,  Nuclear 
800  Boylston  Street 
Boston,  Massachusetts  02199 

Geni'emen: 

Subject;  Systemafc  Assessment  of  Licensee  Performance  (SA^O) 

This  letter  and  its  enclosures  document  NRC's  assessment  of  t-e  le'-'r'^a-ce  :' 
licensed  activities  at  the  PUgrim  Nuc>ar  Power  Station  for  tie  oe'-ic  Se:-.e-:e- 
1,  1981,  to  June  30,  1982.  The  enclosed  SALP  Report,  dated  A^qjst  12,  1951. 
Includes  performance  assessments  for  each  of  the  nine  functis-'al  areas  wn-:- 
were  evaluated.   These  individual  assessments  were  discussed  witn  you  inc   y:-- 
staff  6y  Mr.  R.  W.  Starostecki  of  this  office  on  SepiemDer  1,  1982.  at  fe 
Boston  Edison  Company  offices  in  Braintrae,  MA. 

Our  overall  assessment  of  the  performance  of  NRC  licensed  actwties  at  t"ie 
pilgrim  facility  Is  that  improvement  has  occurred  since  the  organi rational  and 
personnel  changes  which  tooii  place  earlier  this  year.   There  'ow  appears  to  De 
a  satisfactory  level  of  management  attention  and  involvement  in  plant  sa'ety 
matters.  This  has  ennanced  the  plant's  performance  with  respect  to  ooeratlona' 
safety.   We  recognize  tna^  efforts  trt   underway  to  improve  tne  management 
systems  and  utilization  of  resources  at  the  Pilgrim  'aclHty.   These  changes 
and  plans  are  documented  in  the  Performance  Improvement  Plan  which  were  sub- 
mitted to  the  NRC  on  July  30,  1982.  However,  we  also  rea'ize  that  't  wT'  5e 
several  months  before  some  of  these  improvements  will  be  completed.  Alt-^ougn 
performance  has  improved  recently,  some  shortcomings  have  iee'^   noted  and  we 
have  Included  them  in  this  report.   In  particular,  we  beHeve  adS'fonal 
attention  is  warranted  on  your  part  in  tne  areas  of  day-to-aay  o'ant  opera- 
tions and  fire  protection/prevention  activities.   We  wl'l  be  inc-easi-g  ju' 
attention  to  these  areas  to  ascertain  if  identified  wea«.ne^ses  ire   ae-rg 
cor-ected. 

In  the  meeting  of  September  1.  1982,  the  NRC  staff  bene'-'ted  ''om  your  co-nmerts 
concerning  the  SALP  Program  and  the  functional  area  performance  assesS'Te-ts . 

I  have  also  reviewed  your  letter  of  Septemeer  20,  1982  and  have  --c'jcec 
responses  to  your  comments  in  this  pacitage.   The  SALP  Board  also  co^siae'ea 
your  concerns  and  I  had  the  benefit  of  their  input.   The  results  of  these 
considerations  are  presented  below. 


407 


TABLE  5 

VIOmTIONS  (9/V81   -  6/30/82) 
PILGRIM  NUCLEAR  POWER  STATION 
A.    nxattr  tnd  Severity  Level  of  Violations 

4.    Interim  IRC  Policy  Severity  Level   (September  ^,  T981   -  Mareti  9.  !982) 


Severity  Level  I 

Severity  Level  II 

Severity  Level  III 

Severity  Level  IV 

Severity  Level  V 

Severity  Level  VI 
Oeviitlon 


0 
0 
6 
5 

17 
2 
1 


*•    H»C  Policy  Severity  Levels  (March  10.  1982  -  June  30.  1982*) 


J«»»rity  Level  I 

5*'«nty  Level  II 

Sevtrity  Level  III 

Severity  Level  IV 

Sf  erity  Level  V 
Oeviitlon 


0 
0 
1 
4 
3 
1 

38 


^'^1  Violations 
^'^^^^^^^gUL-Iunction.l   Ar,. 
'^'    ^^*^r  1.1981  -March  9.  1982 


Total  Deviations 


Severity  Levels 
II        III IV 


VI 


3 


3 


l^_!!ll!ltenjne, 

4.  Sury,ivw^ 

5.  ^^^iatectiQ, 

6.  Egerqtt^y^^-ji 

7.  Securi 


9.      Licenilna  Aeti  4 


0 

TT 


DEV 


408 

TABLE  5  (Continued) 
B.  VloUtions  Vs.  Functlonil  Art» 

(2)  March  10,  1982  -  Jun«  30,  1982* 


Severity  Levels 


PJNriONAL  AREAS 

I 

II 

HI 

IV 

V 

:ev 

1.  Plant  Ooeraffons 

0 

0 

0 

1 

1 

1 

2.  RadloloQical  Controls* 

0 

0 

0 

1 

0 

0 

3.  Maintenance 

0 

0 

0 

1 

0 

3 

4.  Surveillance 

0 

0 

0 

0 

2 

0 

5.  Fire  Protection* 

0 

0 

0 

0 

0 

0 

6.  Emergency  Preparedness 

0 

0 

0 

0 

0 

0 

7.  Security  t  Safeguards 

0 

0 

1 

0 

0 

0 

0 

0 

0 

1 

0 

B.  Refuel 1nc 

0 

9.  Licensing  Activities 

0 

0 

0 

1 

0 

0 

Totals 


Total  Violations  ■  38 
Total  Deviations  ■  2 


•   Dots  not  Include  the  following  reports,  not  yet  issued: 

82-19  •  Resident  Inspector 
82-20  -  Special  Health  Physics 


36 


409 


TABLE  5   (Contlnuxj) 
C.       Sumnary 

Inspection          Inspection  ... 

fif^        Date Subject Peo.       Sev.       -r«a 

a-1.19  June  15  -  Failure  to  have  an  operable  10  CFS       III         1    :9' 

Sept.  30  combustible  gas  control  system  SZ.a 

(multiple  exuicles  of  design 
errors,  procedural  and  drawing 
errors,  and  inadequate  safety 
reviews] 

8',. 18  June  15  -  Failure  to  Inform  the  NRC  of  T.S.       Ill         1    (?: 

Sept.  30  tfie  erroneous  statement  that  an 

Installed  system  net  the  requlre- 
mnts  of  10  CFR  50. U  -  Material 
False  Statement 

81-19  August  18  -  Failure  to  follow  station  pro-  T.S.       V  1 

Sept.  30  cedure 

81-19  August  18  -  Failure  to  perform  a  safety  10  CFR       IV  1 

Sept.  30  evaluation  prior  to  disabling  50.59 

protection  for  an  RhR  pump 

81-21  August  31  -  Failure  to  post  a  high  radia-  T.S.       IV  2 

Oct.  2  t1on  area 

81-21  August  31  -         Failure  to  adhere  to  radiation  T.S.      V  2 

Oct.  2  protection  procedures  for 

radiation  work  permits. 

81-21  August  31  -         Failure  to  post  copies  of  NOV's  10  cn«      V  2 

Oct.  2  Involving  radiation  protection  19 

81-22  Sept.  16  -  RCIC  containment  Isolation  valves  T.S.      HI        1 

S«Pt.  17  were  left  open  when  their  control 

Instrumentation  was  Inoperable 

81-2*  Dec.  1,  1981-      Operation  at  drywell  temperatures        10  CFR       IV  1 

Jan.  18,  1982      (Povt  FSAR  descHptlon  without  50.59 

adequate  safety  evaluations 

^^*^*  5!«'  ii  ^'*^-      ^•^^"'^  "  adequately  prepare  and  T.S.       V  1(4) 

"'•"•  18,  1982      Implement  proceoures  for  coping 
with  high  drywell  temperatures 


37 


410 


C.       SuniMry 

Inspection 
No. 

Insotctlon 

Oati 

81-24 

Dec. 
Jan. 

1,  1981- 
18,  1982 

81-24 

Dec. 
Jan. 

1.  1981- 
18,  1982 

81-24 

Dec. 
Jan. 

1,  1981- 
18,  1982 

81-24 

Dm. 
Jan. 

1,  1981- 
18,  1982 

81-25 

Oct. 
Oct. 

15  - 
18.  1981 

81-26 

July  20,  1981 

81-35 

Nov. 
Nov. 

1  - 
30 

81-35 

Nov. 
Nov. 

1  - 
30 

81-35 

Nov, 
Nov. 

1  - 
30 

81-35 

Nov. 
Nov. 

1  - 
30 

81-36 

Nov. 

Dec. 

30,  1981- 
4,  1981 

81-36 

Nov. 

Dec. 

30.  1981- 
4,  1981 

TABLE  5  (Continued) 


Subject 


Pea. 


iev. 


Failure  to  ppomptly  evaluate  and 
correct  conditions  adverse  to 
quality 


Security  access  card  keys  not  pro- 
perly controlled 

Combustibles  were  not  removed 
froB  area  near  hot  work 

Improper  et^ulpment  tagging 


Failure  to  have  all  ORG  members 
present  at  a  pr«-refuel1ng 
mtting 

Transported  radioactive  materials 
mIU)  liquid  1n  druns 

Control /Storage  of  combustible 
gas  cylinders  was  not  1n  accord- 
ance with  station  procedures 

Failure  to  establish  and  Imple- 
ment procedures  for  the  control 
of  combustible  scrap,  waste,  debrts 

Failure  to  establish  and  Imple- 
ment  procedures  for  the  control 
of  combustible  o1l 

Control  of  foreign  material 
during  repairs  to  MSIV's  was  not 
In  accordance  with  procedure 

A  master  surveillance  schedule  was 
not  established 

T.S.  Amendnents  were  not  properly 
entered  into  controlled  voliaies 


10  CFR 
50  App  B 

V 

Security 
Plan 

»  •  » 

7 

T.S. 

V 

5 

T.S. 

V 

1    ( 

T.S. 

V 

8 

10  zn 

30.41 

ii: 

2 

T.S. 

V 

5 

T.S.  V 

T.S.  V 

T.S.  V 

T.S.  VI 

T.S.  VI 


9   di 


38 


411 


TABLE  5  (Continue<i 


C,      SuflB«ry 

Inspection 
No. 

Insptctl 
Date 

on 

Subject 

Pea.       Sev. 

Ar» 

81-36 

Nov. 

Dec. 

30. 
4. 

1981- 
1981 

Program  and  procedures  were  not 
established  for  housekeeping  and 
system  cleaning  that  meet  the 
standards  stated  in  the  QA  Manual 

10  CR       V 
50  Aoo  3 
QAM 

3  i: 

82-01 

Jan. 
Feb. 

18. 
28. 

1982- 
1982 

Workers  were  not  properly  In- 
structed of  the  storage  and 
transfer  of  radioactive  resins 

10  CFR       V 
19.12 

2 

82-01 

Jan. 
Feb. 

18. 
28. 

1982- 
1982 

Procedures  were  not  adequately 
established  and  lnvleninted  to 
provide  required  numbers  of  SCBA 
units  for  fighting  fires 

T.S.       V 

5 

82-02 

Jan. 
Jan. 

1  - 
15. 

1982 

UncaHbrated  bnjsh  recorders 
Mere  used  during  RPS  surveillance 

10  CR       V 
SO  App  B 

4 

32-02 

Jan. 
Jan. 

1  - 
15. 

1982 

Ma1nt«nanc«  activities  were  per- 
fonwd  without  using  approved 
procedures 

T.S.       IV 

3 

82-02 

Jan. 
Jan. 

1  - 
15. 

1982 

Instrumentation  was  not  calibrated 
at  fr»quency  specified  In  station 
procedures 

T.S.       V 

4 

82-02 

Jan. 
Jan. 

1  - 
IS. 

1962 

Improper  control  of  access  to 
Vital  Areas 

Security  III 
Plan 

7 

82-04 

Jan. 
Jan. 

25 

29. 

*1982 

Failure  to  Isplenent  procedures 
for  Li^  and  drawing  change 
revisions 

T.S.       V 

4  (1 

82-04 

Jan. 
Jan. 

25 

29. 

1982 

Drawings  and  procedures  did  not 
Identify  the  as-built  condition 
of  valves  In  piping  systems 

10  CR       IV 
50  App  B 

1 

82-05 

Feb. 
Feb. 

1  - 
5. 

1982 

Untimely  corrective  action  to 
Internal  QA  Audit  Deficiency 
Reports 

10  CR      V 
SO  App  B 

1 

82-06 

Feb. 
Feb. 

10 
12. 

1982 

Training  and  recual.  program  for 
personnel  who  operate  and  process 

ComnlttJiient  DEV 
lEB  79-19 

2 

radioactive  waste  not  Implemented 
as  coonltted 


39 


412 


TABLE  S  (Cont1nue<i) 


C.       Sunwary 

Inspection 
No. 

Inspection 
Date 

N/A 

Feb.  12.  1982 

82-10 

March  1  - 
April  4.  1982 

82-10 

March  1  - 
April  4.  1982 

82-11 

Feb.  25  - 
Feb.  28.  1982 

32-12 

April  5  - 
May  9.  1982 

82-13 

April   12  - 
April   16.  1982 

82-16 

i 

May  10  - 
June  13.  1982 

Subject 


Pea. 


sev. 


Ar.a 


Prompt  Notification  Systm 
(sirens)  not  Installed  by 
February  1,  1982 

Performed  maintenance  on  valve  with 
red  tag  attached 

Plant  shielding  study  md. 
(truck  lock  door  panel)  not 
completed  as  ststed  1n 
r«sponse  to  NRR 

An  unauthorized  adjustment  was 

made  to  a  leaking  flange  during 
the  conduct  of  the  PCILAT 

Failure  to  follow  actions  re- 
quired by  T.S.  with  Inoperable 
reactor  vessel  water  level 
Instrumntatlon 

Inadequate  design  control .  for 
Interfaces  and  verification 

Failure  to  lock  or  control  access 
to  a  high  radiation  area  (stuck 
TIP  drive) 


10  Cr^ 
50.54 


T.S. 


NURES 
0737 


10  CFR 
SO  App  J 


OEY 


IV 


T.S.   IV 


10  CFR   IV 
50  App  B 

T.S.   IV 


1  (3; 


9  (5; 

2 


(  )*  secondary  area  Involved 


40 


413 


Testimony  Submitted  by 

Stepfien  J.    Sweeney 

President  and  Chief  Executive  Officer 

Boston  Edi  son  Company 

to  the 

U.S.  House  of  Representatives 

Subcommittee  on  Energy  Conservation  and  Power 

of  the 

Committee  on  Energy  and  Commerce 

July  16.  1986 


L^.-^<-^  *7^ 


.r 


414 


•N-qccuc'::N 


Boston  Ed' son  Comoany  appreciates  tne  opportunity  to  address  a 
number  of  issues  involving  the  Pilgrim  Nuclear  Power  Station  which  are  of 
concern  to  this  committee,  the  Nuclear  Regulatory  Commission  and  to  ne 
oersonaliy.  At  the  outset  let  me  stress  that  most  of  the  issues  raised  o/ 
tne  NRC  in  various  reports  and  by  this  committee  were  of  concef-n  to  -ne  -ncre 
than  a  year  ago  and  that  corrective  actions  were  underway  as  early  as 
Septemoer  1985.  As  discussed  in  the  following  pages,  those  actions  are 
meeti  ng  wi  th  success . 

In  today's  environment,  public  concern  about  nuclear  power  is 
heightened  substantially.  Public  confidence  in  the  technology  and  the 
institutions  involved  with  it  is  at  a  low  point. 

Boston  Edison  Company  has  a  great  deal  of  work  to  do  in  this 
environment  to  gain  public  confidence  in  our  ability  to  manage  and  run 
Pilgrim  Station.   I  personally  will  not  be  satisfied  until  we  have  acnieved 
a  level  of  public  and  regulatory  confidence  tnat  allows  Pilgrim  Station  to 
place  among  the  best,  we  have  made  an  internal  commitment  to  measure 
ourselves  against  the  best,  which  is  a  significant  change  in  now  we  are 
approaching  our  current  problems. 

As  will  be  evident  in  reviewing  our  testimony,  we  were  historically 
plagued  by  not  lool^ing  outside  to  measure  our  success  and  to  jndertaKe  tie 
intensive  self-criticism  necessary  to  assess  performance  honestly  and 
objectively.   That  has  changed.   We  are  moving  in  a  new  direction,  one  based 
on  rising  standards  of  excellence  which  are  set,  not  by  regulation,  but  Dy 
the  performance  of  those  plants  judged  to  be  among  the  best. 


415 


It  s.'ioul::  3e  noted  triat  tf^e  concer-s  we  are  add'-ess-ng  :;ca/  i'-e 

j,c<^3rent  from  tnose  for   whicn  xe  «*e'-e  '.ned  in  1982   T^g  -ssjes  t-ion  ^e--? 

,fa'-'j-related  and  failure  to  compiy  with  rogulaticns.   ^oday,  f^e  'ss-es 
5  a '  "  •  / 

re  not  directly  related  either  to  compliance  or  to  safety.   They  in-.tea: 
•nvo^'^e  3  rising  stanaard  of  performance  going  far  beycna  -nere  ::mc''a-:? 

; -1  rules  to  a  mud  proader  dimension  in  tie  regulatory  process,   '-a:  -e^ 
I'mension  is  one  that  dictates  comparisons  and  success  is  neasu^ed  py 
relative  performance.  We  endorse  it. 

Before  discussing  our  current  activities,  let  me  offer  perspectwe: 

on  three  time  i'rames. 

The  first  time  frame  is  1972  to  1979  and  Three  Mile  Island,   ^ur 
■7a-cr  management  shortcoming  then  was  the  ^ailure  to  recognize  'ully  tnat 
:he  operational  and  managerial  demands  placed  on  a  nuclear  power  plant  a'"? 
;e^y  different  from  tnose  of  a  conventional  fossil-fired  power  plant. 
?c$tcn  Edison  strjctured  its  nuclear  organization  as  part  of  a  tradit'cna' 
:De^ating  arm.   ;^hile  many  members  of  the  Pilgrim  Station  organization 
'eccgnized  the  differences  in  the  technologies,  they  had  limited  success  'n 
jrgu'pg  for  the  resources  necessary  to  meet  a  set  of  standards  that  a'reaa.^ 
•ere  "Sing  fairly  rapidly.  This  was  also  a  period  of  poor  quality  fjel 
•h'ci  resulted  in  significant  internal  radiological  problems  that  affecte: 
t^e  p' ant  for  years . 

Then  came  Three  Mile  Island.  From  March  1979  until  early  1982  the 
same  structure,  under  one  vice  president,  attempted  to  deal  with  the 
:ost-TMi  demands  on  operations  and  engineering,  while  at  the  same  t'me 
3ursu'ng  a  construction  permit  for  a  second  unit  at  Pilgrim  Station.   The 
sraf*  increased  dramatically  to  200,  300  and  then  400  people.   It  was  an 
-nreascnaple  wor<load  for  the  structure  and  we  paid  a  costly  penalty  'zr   -c: 
'8::gn;z;rg  -^  ..  5550. qco  in  early  1932. 


416 


From  1982  unti  '  111(3-1985,  we  ooerared  «1ti  a  new  ana  ■•"c^/ec 
■na-iageTien:  structure  mat  recognized  tne  uniQue  nature  cf  "uc'sar  ccwe-- 
plants  and  the  demands  of  the  post-TMI  period.   »^e  committed  the  ("inancal 
and  human  resources  necessary  to  upgrade  equipment  and  hardware  ana  to 
•nstali  various  improvement  programs  to  meet  NRC  concerns.  More  than 
5300  million  went  into  hardware  improvements,  the  staff  grew  "rzm   JCC  to 
nearly  600  people  and  the  organization  was  restructured  under  a  san-or  ;i:e 
president  and  two  vice  presidents.  We  achieved  a  significant  Tieasur?  o- 
success  for  wnich  we  were  recognized  by  the  NRC  and  in  the  plant's 
outstanding  operating  performance  in  both  1983  and  1985. 

But  in  managing  the  equipment  improvements  and  the  new  TianageTient 
systems  and  programs  we  put  in  place,  we  didn't  focus  enough  on  wnat  was 
going  on  outside  the  company  in  the  industry  and  within  the  NRC.   what  x? 
didn't  see  because  we  were  so  internally  focused  was  the  fact  that  '.-  = 
industry  itself  and  the  NRC  were  looKing  under,  behind  and  around  al'  of  t-e 
narjware  and  management  programs  reaching  for  e<cellence. 

In  our  case,  not  seeing  that  put  us  in  a  defensive  posture,   .^e 
weren't  identifying  weaknesses  that  were  inhibiting  continued  improvement 
ourselves.  We  weren't  being  self-critical,  others  had  to  tell  us  what  -a; 
wrong.  We  weren't  holding  managers  accountable  enough  for  the  end  •'esu't  of 
an  action  or  inaction.   We  weren't  wording  well  enough  together. 

Those  problems  were  very  real,  very  serious  and  of  great  concern  :o 
me  and  to  the  Board  of  Directors.   I  became  particularly  concerned  about 
management  performance,  not  management  systems  and  programs,  but  the  results 
of  those  systems  and  programs  as  measured  by  effectiveness   In  mid-i935.  I 
asked  the  V'ce  President  of  Nuclear  Operations  to  investigate  my  concer-^s. 
which  ne  shared,  and  issue  a  report.  As  he  progressed  through  the  stu^y.  "e 


417 


-,3  oce'-  managers  began  iaentifying  needs.   In  SecteiiDer  1985.  «e  '^z-n-i- 
.-e  operator  staff  by  a  third,   in  Oecemoer,  we  reorganized  oUnt  "anage-?-: 
imorove  reporting  relationships  and  build  in  greater  accountaoi ' i tv. 

In  February  1986,  the  NRC  issued  their  reoort.   They  said  the  sare 
►ning:   We  had  attitude  problems  that  were  seriously  interfering  w-:n  zw 
joil'ty  to  get  the  results  we  should  be  seeing  given  our  fi-iancia'  anc  -..ra- 
'ssource  commi  tuents. 

By  March,  we  had  talcen  a  number  of  other  actions,  ail  of  wn;:n  a-? 
jetailed  in  the  following  pages.  We  began  eliminating  those  old  att'tjces 
-lat  «ere  not  serving  us  well  and  began  to  inject  the  nuclear  organization 
,ith  the  sl^'  's  and  perspectives  necessary  to  achieve  a  measure  of 
cerfor-nance  which  would  place  us  among  the  best.   In  the  same  time  frame  *e 
•nade  further  human  resource  commitments.   We  increased  our  emergency 
aijnning  complement  five-fold,  we  increased  the  number  of  radiological 
technicians  35  percent  and  we  implemented  an  apprentice  program  for  the 
'cng-term  development  of  skilled  personnel. 

The  shutdown  on  April  12  gave  us  an  opportunity  to  accelerate  mar 
Cange.  A  different  approach  to  problem  solving  was  taken.   It  stressed  a 
■nore  deliberative  and  Integrated  effort  at  identifying  root  causes  and 
ran";  corrective  action.   In  early  May,  a  new  plant  manager  and  a  new 
:ce'-it'ons  section  head  were  brought  on  board,  nearly  rounding  out  a  new  ■  ■: 
lemcer  plant  management  team.  Of  the  16.  II  were  new  in  their  pos't'ons  'i 
fie  :ast  8  months  and  5  were  new  to  the  company.  We  nave  new  perspecf ves . 
''e  have  people  with  strong  nuclear  navy  backgrounds,  people  with  NRC 
'"scection  experience  and  people  who  grew  up  professionally  not  in 
:cnventional  fossil-fired  power  plants,  but  in  nuclear  plants. 


418 


-  3  - 


On  May  27.  having  accsDted  that  management  is  jus:  as  imccrta-^:  n 
-u'cment.  ««e  *cok,  the  unoracedented  steo  of  giving  the  new  plant  manager 
d  his  new  team  additional  time,  while  the  unit  was  shut  down,  to  become 
familiar  -^^'^  '^®  issues,  to  accelerate  the  development  of  new  programs  an:;, 
TOSt  importantly,  to  infuse  the  organization  with  attitudes  and  dehavio' 
.riat  will  make  those  programs  work,.  These  are  attitudes  tnat  demand 
-elf-criticism,  demand  accountability,  demand  teamworK  and  demand  results 
«hich  go  far  beyond  mere  compliance  with  a  set  of  rules,  regulations  ana 
technical  specifications. 

Excellence  is  our  goal.  But  excellence  is,  after  all.  an  attitude 
..nich  accepts  nothing  less.  Achieving  excellence  will  not  be  easy;  we  <ncw 
that.  We  <now  our  problems.  We  have  made  the  human  resource  and  financial 
commitment  to  solve  them.  We  Know  what  has  to  be  done  and  we  are  doing  it. 
A;  i  result,  I  am  confident  we  will,  in  time,  demonstrate  to  you,  to  t"e 
Nuc'ear  Regulatory  Commission  and  the  public  that  we  have  responded 
e^-'ectively  to  the  concerns  which  are  shared  by  all  of  us. 

As  a  final  point.  I  know  that  an  important  question  on  tne  minas  :f 
many  pecp"e  is  "why  should  Boston  Edison  be  believed  today  given  the 
problems  over  the  years  at  Pilgrim  Station''" 

I  hope  I  already  answered  that  question  in  part.  It  is  perhaps  t-e 
most  difficult  question  and  can  only  be  answered  fully  by  performance  ove-- 
time.  But  in  dosing  I  would  underscore  two  major  differences  today  from 
the  past.  The  first  is  our  forceful  acceptance  of  the  need  *or  us  to 
measure  our  performance  against  an  ever  increasing  set  of  standards  set  by 
those  plants  judged  by  industry  and  the  NRC  to  be  among  the  best. 


419 


•3     - 


'he  second  is  the  fact  that  we  have  alooted  the  iasic  or;r:^o'=s 
criter'a  for   good  -nanagement  tha:  are  aopHed  to  the  nuclear  navy.   --e_/ 
rg  the  same  principles  and  criteria  that  are  in  evidence  at  all  of  the  ::c 

rated  plants. 

This  is  a  demanding  industry  with  a  vital  role  in  the  soc'al  and 
.,-oncmic  health  of  the  count-y.   It  operates  in  a  demanding  regulatory 
climate  as  evidenced  by  this  hearing  today.  For  us  as  a  company  -itn  a 
single  unit  to  succeed  in  this  environment  means  that  we  must  impos'e  on 
ourselves  the  highest  standards  of  performance  found  in  the  industry,   ^e 

are  doing  just  that. 

The  balance  of  this  filed  testimony  is  arranged  in  the  order  of  the 
si«  sections  on  which  you  requested  information  in  your  letter  of  Ju-ly  2, 
1986.  we  have  repeated  your  request  at  the  beginning  of  each  section. 


420 


SOSTt>\i  £D'SCW 


Ralph  G.  Bird  Ju    /  3  .    '  53? 

3£Co  L:r.    37-1 i i 

•^r.  3t3vsn  i  Varga.  Z.'S-'.zr 
C'vs^c  of  Rsdcro''  ^'c'act:.  I/II 
jniTsa  ;:at33  Nlc'sj'-  Regj'atory  Ccmmin;cn 
-^asi'-;::",  ^.  Z.     ;C:55 

License  CPR-3S 
!:oc!<Let  50-293 

:nfc«ma-:cn  segasoing  'iigsim  station 

S.«--Ty  ENHANCEMENT  PqCGSAH 

Reference:    NRC  w3t:e'",  ^'coosed  EnhancsTient  to  tne  Marfc  I  Containment  - 
?'";r--Ti  3:a:xn,  aated  April  30.  :987 

Gear  Mr.  Varga: 

As  agraed  iur'nq  :^"7  i.  '987  jiscussions  between  Franlc  M'raglia.  USNRC. 
ana  Jcrn  -j'tcn,  3os:cn  i:'30n  Comcany  (3£Co).  -e  are  suOmitt'ng  :nis  '■esccr^j 
to  ycur  'ette*-  t:  3E;c  :at23  Aori  1  30,  '937.  Enclosed  for  jour   ■  nfomat'cn  •; 
a  retailed  :esc'":fcn  or  r-e  Safety  Ennancemenr  ^r^gram  (SE?)  naraware 
tnanges  tnat  5ECo  las  voiunrarily  e'ected  to  ino'ement  for  Pilgrim  Nuc'ea-- 
?ower  Station  (?NPS).   "''^e  ::escrioticn  of  procacural  changes  and  oersonnei 
t'lining  «ill  ;e  'jr-i-snec  .nder  seoarate  cover.   A  current  'nc! ementaricn 
jt'eaule  -or  t-e  SE'  iicdi  f 'cat'cns  -ill  also  3e  '"jmisned  seoarate';/.  A 
conait'cn  is  t-at  tie  Todi f icaticns  scheduled  during  the  current  outage  lo   "c: 
'ecu'ra  3r";r  governmental  aooroval.  Should  this  conaiticn  not  2e  "ne:  'o'"  i".' 
of  tiese  /o'uitary  too;  • '  cifons .  with  the  result  tnat  the  cur-ent 
■  id' STientafon  scnedule  "nust  oe  extenaed.  tnen  3ECo  lill  be  unaole  to 
■Tic'eTient  fe  af-ecteo  .^cc'-"  cations  curing  tne  :jr-ent  outage. 

iaa'ticnal  dccumentat'on  -till  5e  avai'ao-e  ':r  'sviaw  ay  fe  NRC  Sta^-  i: 
3£Co's  arainfw- of*i  ces  0'  tie  PNPS  site.  CognTant  3E.Co  oersonnei  «i  '  :e 
avaiiaole  at  those  iccat-c-s  "or  i-scussion  witn  t-e  Staff 

Cjr-ent  eva'uafo-s  of  fe  :e"e'it  from  tie  SE'  -nodi  *icafcns  are  oasa: 
primar'ly  ucon  ei<t?'S"ve.  a'tnaugn  still  ore  1  i binary ,  analyses  and  aua'itif-e 
engineering  jjogments.   "'-a'  quantitative  analyses  -nust.  in  accordance 
witn  the  statea  long  te-^  goal  of  tne  SEP.  await  final  identification  of 
■ncd'f  1  cat' ens  i"c  rcnoiet"  tn  of   the  Indiviaual  "'ant  Evaluation  (!?£:•. 
3ECo  undef-srancs  fat  '"e   n=C  intends  to  issue  late--  this  year  a 
gener::  'ette'-  renu'-'ng  ai'  alants  to  serforn  an  !?£  as  part  of  tne 


121 


ie  '9'  = 


'j.^yramen:     '3     '53^63.     Ei.-    r'.r..j 

56-8'-::    's'.:  =  ^. 


S3   :r93:'':ea   :.-   :-e 


9i3S     "i9'     '''"SS     TC    tCf^TiCt    ~8 


:j  -avo  i"/  :^8;:-:-i< 


/i/^, 


3;  ^: 


:c:   Nuclear  Reguiatary  Conriss"on 
Docurent  Ccntrol  Des< 
Wasrnrigzcn,  2.    C.   2255: 

Nuc'ear  Requiatory  CcmrnissiGn 

Region  I 

531  ^ark  Avenue 

King  of  Prussia,  ?A  19406 

Senior  'IRC  Resident  Insoector 
^ilgrir:!  Nuclear  Power  Station 

■^r.  R.  H.  Wessman,  Project  ^-'anager 
^Division  of  Reactor  Projects,  I, 'II 
Qff-fce  of  Nuclear  Reactor  Regulation 
U.S.  "Judear  Regulatory  Cctnmisslon 
7920  No»*or<  Avenue 
Bethesda,  ''10  2C8U 


422 


Vdchael  S     Dukaias 

Ciyvemor 

Charles  V    Barry 

Secretary 


'I 


.■J)'.^-f,      ^fa.^.j^i£yui.l£/i±  I' 2 /  f  S    /i/T/   7J7  -TTTS 


EXECUTIVE  SUMMARY  OF  THE  PROGRESS 

REPORT  ON  EMERGENCY  PREPAREDNESS  FOR  AN 

ACCIDENT  AT  PILGRIM  NUCLEAR  POWER  STATION 


EXECUTIVE  SUMMARY 

Or.  December  16,  1935,  I  t  ransi^itted  to  the  Gaverior  a 
conprer.ens  •- ve  reoort  on  safety  at  Pilgrim  Nuclear  Power 
Statio". .   T'-.is  13  a  progress  report  about  the  activities  cy 
state  a-d  local  goverriT.ent,  the  Boston  Edison  Conpany,  -he 
U.S.  Nuclear  Regulatory  ConT.ission  and  the  Federal  Emerge-cy 
Management  ^genrv  since  that  time  to  address  the  concerns  we 
found. 

In  April  of  19S6,  operation  of  Pilgrim  Station  was 
halted  because  of  several  mechanical  problems.   The  U.S. 
Nuclear  Regulatory  Commission  has  ordered  that  the  Boston 
Edison  Cor-pany  keep  the  plant  shut  until  a  variety  of 
corrections  regarding  the  management  and  operation  of  Pilgri' 
Station  have  been  made.   As  of  this  date.  Pilgrim  remains 
closed,  although  Boston  Edison  has  asked  the  NRC  for 
permission  to  restart  the  facility. 


Rad 
fac 
saf 
man 
the 
pla 
ser 
rec 
unl 
add 


In 
iolog 
ility 
e  t  y . 
ageme 
reac 
nning 
ious 
ommen 
ess  a 
resse 


my  0 
ical 
wer 
I  f 
nt  o 
tor. 

-  Pl 
and 
ded 
nd  u 
d. 


ece 

Erne 
e  no 
urth 
f  th 
In 
ant 
the 
that 
ntil 


ber,  1986  report,  I  concluded  that 

gency  Response  Plans  for  the  Pilgrim 

t  adequate  to  protect  the  public  health 

er  identified  serious  problems  regardm 

e  power  plant  and  the  engineering  safet 

my  view,  these  three  issues  --  emergen 

management,  and  reactor  safety  --  were 

weaknesses  and  deficiencies  so  severe  t 

the  plant  should  not  be  allowed  to  res 

these  concerns  had  been  satisfactorily 


y  o: 
so 


There  has  been  a  considerable  amount  of  activi! 
levels  to  address  these  concerns  since  ""  ronnn-  u?,> 

In 


at  a; 

issue': 


423 


-2- 


MCDA/OE?  has  InstitJted  a  plar'.r.i.r.g  p 
and  local  level  and  revisions  are  well  un 
addition,  a  new  system  has  been  installed 
notification  in  the  event  of  an  accident 
We  now  have  the  advantage  of  a  new  N-iclea 
Preoaredness  Program  and  a  professional  s 
first  time  is  dedicated  to  off-site  emerg 
and  planning.  This  new  program  and  staff 
the  Governor's  initiative  in  the  Fiscal  Y 
The  Governor  has  requested  additional  fun 
program  as  a  supplementary  appropriation 
fiscal  year. 


roce 

for 
at  P 
r  Sa 
taff 
ency 

are 
ear 
ds  f 
for 


ss  a 

wav  . 

off 

ilgr 

f  ety 

wh  1 

pre 

the 

1988 

or  t 

the 


t  the 

In 

-sits 

im  St 

Ener 

c  h  f  o : 

pared: 

r  e  s  u : 

b  u  d  g ; 

he  ne- 

c  u  r  r  e  r 


at ; 
aer 


the 

!33 


Nonetheless,  I  continue  to  make  the  finding  that 
adequate  plans  for  response  to  an  accident  at  Pilgrim  Station 
do  not  exist,  and  I  reaffirm  my  earlier  position  that  the 
Pilgrim  facility  should  not  be  allowed  to  restart  until  s-^ch 
plans  have  been  fully  developed  and  have  been  demonstrated  to 
be  workable  and  effective  through  a  graded  exercise  of  all 
plans  and  facilities. 


This  finding  is  based  on  the  fac 
area  in  which  I  found  a  deficiency  to 
1936  report  substantial  work  remains 
determination  of  adequacy  can  be  made 
of  a  new  Evacuation  Time  Estimate  and 
Study  by  state  and  local  authorities 
ETE  is  one  of  the  most  critical  piece 
entire  process  and  the  foundation  of 
planning.   Our  preliminary  review  of 
more  resources  are  required  to  succes 
traffic  management  plan.   The  shelter 
prepared  by  Boston  Edison  has  been  re 
"for  further  study  because  is  was  foun 
inadequate . 


t  that  in  every  critical 

exist  in  my  December, 
to  be  done  before  a 

For  example,  analysis 
Traffic  Management 
IS  still  underway.   Tr.e 
3  of  information  in  the 
effective  emergency 
the  ETE  suggests  that 
sfully  implement  the 

survey  which  was 
turned  to  the  company 
d  to  be  woefully 


Plans  and  implementing  procedures  for  special  need 
populations  remain  incomplete,  and  it  may  be  necessary 
undertake  an  additional  survey  of  people  who  would  need 
assistance  in  emergency  response  or  to  do  further  stati 
analysis  of  this  matter.   The  development  of  implementi 
procedures  and  the  identification  of  resources  to  care 
school  age  populations  also  requires  additional  work, 
regard  to  the  adequacy  of  reception  centers,  the  questi 
need  for  a  facility  to  serve  people  in  the  northern  por 
of  the  EPZ  remains  open.   We  cannot  make  decisions  on  t 
need  for  or  identification  of  a  third  reception  center 
Boston  Edison  has  provided  us  with  an  analysis  of  the 
adequacy  of  the  existing  two  reception  facilities. 


s 

to 

s  1 1  c  a : 
ng 
for 
In 

on  of 
t  ion 
he 
u  n  t  i  1 


424 


-3- 


With  regard  to  plant  management,  we  have  seen  numero-s 
changes  in  Boston  Edison's  personnel  and  organization  for 
management  of  Pilgrim  Station.   The  most  notable  change  is 
the  appointment  of  Mr.  Ralph  G.  Bird  as  Senior  Vice 
President,  Naclear,  who  directly  reports  to  the  company's 
chief  executive  officer.   Yet  despite  these  changes,  I  car.-.o- 
say  at  this  time  that  the  management  problems  have  been  f-illy 
resolved.   For  example,  we  are  concerned  about  recent 
incidents  including  violation  of  NRC  regulations  m  the  ar?a 
of  plant  security,  and  allegations  of  excessive  overtime 
worked  by  utility  employees.   We  are  also  concerned  by  Boszz- 
Edison's  action  to  refuel  Pilgrim  Station  without  having 
responded  to  my  objections  and  the  objections  of  several 
state  legislators. 

The  Systematic  Assessment  of  Licensee  Performance  ( 3A1? ) 
perfomed  by  the  NRC  is  the  most  comprehensive  study  and 
reoort  on  nuclear  management  at  Pilgrim  Station.   The  last 
SALP  report  was  issued  on  April  8,  1987  and  it  showed 
deterioration  in  several  aspects  of  nuclear  management  since 
the  last  report.   Until  a  similarly  comprehensive  analysis  of 
management  under  the  new  organization  has  been  conducted  and 
the  above  concerns  resolved,  I  cannot  say  that  our  management 
concerns  have  been  addressed. 

With  regard  to  reactor  safety  issues,  we  have  carefully 
reviewed  Boston  Edison's  "Safety  Enhancement  Program"  (SEP). 
The  SEP  has  been  undertaken  since  the  issuance  of  a  "Draft 
Generic  Letter"  from  Mr.  Robert  Bernero  of  the  NRC  concerning 
safety  at  Mark  I  containment  structures  such  as  the  Pilgrim 
containment.   We  have  two  major  concerns  in  the  area  of 
reactor  safety. 

First,  despite  the  fact  that  the  NRC  letter  was  prompted 
by  a  finding  that  there  was  a  high  probability  of  Hark  I 
containment  failure  during  certain  severe  accident  scenarios, 
the  NRC  has  yet  to  adopt  an  official  position  regarding 
safety  enhancement.   Moreover,  according  to  NRC  Region  I 
Administrator  William  Russell,  with  whom  my  staff  and  other 
state  officials  met  at  NRC's  regional  offices  .-.  King  of 
Prussia,  Pennsylvania  on  October  8,  1987,  enhancement  of  the 
Mark  I  containment  at  Pilgrim  is  not  an  issue  that  the  NRC 
believes  must  be  finally  resolved  before  restart. 


Our  second  concern  is  the  uncertainty  that  continues  to 
exist  about  at  least  one  feature  of  the  Boston  Edison  SEP, 
the  direct  torus  vent.   No  concensus  has  been  reached  on 
whether  installation  of  the  torus  vent  creates  unreviewed 


425 


-4- 


safety  issues  or  if  the  torus  vent  is  authorized,  how  it  w.  1 1 
be  used  in  the  event  of  a  severe  nuclear  accident. 

The  findings  of  my  December,  1986  report  have  been 
strengthened  by  two  other  analyses  of  safety  at  Pilgrim 
Station.   The  Special  Joint  Legislative  Commission  to  Study 
Pilgrim  Station  has  issued  its  report  which  further  studies 
and  documents  many  of  the  same  safety  concerns.   In  addition, 
the  Federal  Emergency  Management  Agency  has  issued  a 
Self-Initiated  Review  of  plans  for  response  to  an  accident  at 
Pilgrim  Station.   Based  on  several  of  the  issues  raised  m  my 
report  FE^A  has  changed  its  interim  finding  and  now  agrees 
that  the  off-site  plans  for  an  accident  at  Pilgrim  are  not 
adequate . 

FEMA  has  transmitted  their  new  finding  to  the  Nuclear 
Regulatory  Commission.   However,  the  NRC  has  yet  to  indicate 
whether  or  not  development  of  adequate  off-site  plans  will  be 
a  condition  to  the  restart  of  Pilgrim,   we  are  not  satisfied 
with  the  view  recently  expressed  by  the  NRC  Region  I  staff 
that  emergency  planning  problems  must  be  "addressed"  before 
restart.   Such  problems  must  be  satisfactorily  resolved 
before  restart.   Off-site  response  plans  are  just  as 
important  as  nuclear  management  and  reactor  safety  in 
protecting  the  public  from  an  accidental  release  of  radiation. 

Therefore,  for  these  reasons  —  the  absence  of  adequate 
emergency  response  plans,  lack  of  demonstrable  assurance  that 
management  problems  have  been  solved,  and  uncertainty  about 
the  safety  of  the  Mark  I  containment  structure  —  I  continue 
to  find  that  Boston  Edison  has  not  met  the  heavy  burden  of 
showing  readiness  to  restart  the  Pilgrim  Nuclear  Power 
Plant.   I  also  continue  to  believe  that  it  remains  to  be  seen 
if  adequate  emergency  response  plans  can  be  developed  and  if 
all  other  safety  issues  can  be  resolved  to  our  satisfaction. 

Finally,  I  recommend  that  in  light  of  the  number  of 
outstanding  issues  and  their  complexity,  and  Boston  Edison's 
evident  determination  to  press  ahead  with  the  effort  to 
restart,  that  there  should  be  a  full  scale  public  hearing  by 
the  NRC  before  any  decision  is  made  regarding  the  restart  of 
Pilgrim  Station. 


October  14,  1987  CHARLES  V.  BARRY 

SECRETARY  OF  PUBLIC  SAFETY 


1051J 


426 


THE  COMMONWEALTH  OF  MASSACHUSETTS 
EXECUTIVE  DEPARTMENT 

CIVIC  D6FENSE  ACCNCT  *n0  OFFICE  OF  EME«GENCY  PREPAREDNESS 

400  WOBCESTEB  ROAO 

PO  BOX  I48e 

FRAWINGKAM.  MASS   017010317 


MICHAELS   DUKAKIS 
GOVERNOR 


ROBERT  J    BOULAr 

DIRECTOR 


September  18,  1987 


Mr.  RalDh  Bird 
Senior  Vice  President 
Boston  Edison  Company 
800  Boylston  Street 
Boston,  Massachusetts 

Dear  Mr.  Bird: 

My  staff  has  reviewed  the  August,  1987  "Study  to  Identify 
Potential  Shelters  in  EPZ  Coastal  Region  of  the  Pilorim  Nuclear 
Power  Station,"  which  was  prepared  for  you  by  Stone  and  Webster, 

We  find  that  this  study  is  deficient  in  several  respects  and 
that  additional  work  is  required  to  provide  information  to 
local  officials  which  is  sufficient  to  suoport  development  of 
implementable  shelter  utilization  plans.   I  have  attached  a 
copy  of  a  memorandum  orepared  by  my  staff  which  details  our 
specific  concerns  regarding  this  study. 

If  you  have  any  questions  or  observations  reoarding  our 
evaluation,  please  contact  Buzz  Hausner  of  my  staff. 

Thank  you  for  your  cooperation  in  this  matter. 


Sine 


Director 


cc:   Assistant  Secretary,  Peter  W.  Agens,  Jr. 
Deputy  Director,  John  L.  Lovering 
Mr.  Buzz  Hausner 


427 


EXECUTIVE  DEPARTMENT 

Civil  OC'CnSE  AOCnC*  ^**0  0*'iCE  0'  (MEWJtMCT  PnCPAREDNCSS 

400  WOPCESTCn  »»O*0 

PO   BOX  1490 

FflAMINOMAM,  UASS   OirOlfliW 


'-.       "c 


^*^ t^*- 


^■IfMO^^" 


MrCHAEL  S    DUKAKIS 

OOVEBNOfl 


ROBEflT  J    eoULAY 
OIOCC'OB 


TO: 

FROM: 
IN  RE: 

DATE: 


DIRECTOR  BOULAY 

BUZ^^USNER 

SHELTER  SURVEY  OF  PILGRIM  EPZ  PREPARED  BY  BOSTON  EOISOrj 
COMPANY 

SEPTEMBER  11,  19fl7 


We  have  made  a  preliminary  review  of  the  shelter  survey  of  the 
Pilgrim  EPZ  which  was  prepared  by  the  Boston  Edison  Comoany  and 
its  consultants.   While  this  rtocunient  comoiles  some  very  useful 
data,  we  feel  that  more  work  must  be  done  to  estimate  the 
effectiveness  of  shelter  as  a  protective  action. 

Our  principal  concern  is  that  we  must  be  able  to  put  data  in  the 
hands  of  local  officials  which  are  sufficient  for  the  development 
of  shelter  utilization  plans  for  all  areas  of  all  five 
communities  within  the  Pilgrim  EPZ.   With  this  in  mind,  we  have 
the  following  comments. 

The  survey  only  covers  an  area  approximately  one  mile 
wide  along  the  coast.   The  shelter  capabilities  of  the 
entire  EPZ  must  be  surveyed  and  reported. 

The  survey  does  not  separate  out  those  structures  which 
could  "most  reasonably"  be  used  as  shelters  from  those 
where  shelter  is  less  appropriate. 

For  Instance,  it  would  help  to  have  a  separate  list  of 
public  buildings  and  facilities  for  each  town, 
including  an  estimation  of  the  actual  useable  shelter 
space  and  protective  factors  for  shelter  under 
government  authority. 

Many  of  the  shelters  listed,  such  as  jewelry  stores  and 
pharmacies  are  clearly  not  suitable  for  public 
shelter.   In  a  severe  emergency,  every  available 
resource  will  of  course  be  put  to  use.   However,  to 
develop  an  implementable  shelter  utilization  plan, 
local  officials  must  be  able  to  match  estimated  needs 
with  the  most  appropriate  resources  available. 


428 


Director  Boulay 
Page  2 


Regarding  protection  of  the  heach  oooulatlon,  the 
survey  identifies  shelters  within  a  mile  of  the  coast 
but  does  not  indicate  the  distances  that  beach  goers 
would  have  to  travel  to  find  shelter.   In  addition,  thp 
survey  must  demonstrate  that  adequate  proximate  shelter 
Is  available  for  the  total  population  at  the  individual 
beaches . 

For  instance,  Ouxbury  beach  is  about  seven  miles  lonq 
and  the  survey  should  indicate  the  distance  peonle  at 
Saqulsh  Head  are  required  to  travel  to  reach  adequate 
shelter.  Further,  an  implementable  shelter  utilization 
plan  must  demonstrate  that  the  nearest  shelter  would 
not  be  full  to  capacity  before  the  people  at  the  most 
remoten^oirits  of  the  beaches  arrived. 

The  survey  must  identify  adequate  shelter  which  is 
handicapped  accessible. 

The  survey  does  not  distinguish  between  available  space 
and  usable  space.   For  instance,  residents  of  Plymouth 
have  indicated  to  us  that  some  basements  listed  in  the 
survey  are  no  more  than  crawl  spaces.   Crawl  spaces 
cannot  be  considered  for  public  shelter.   Further,  in 
most  buildings,  a  good  deal  of  floor  area  will  be 
occupied  by  machinery,  counters,  office  furniture,  et 
cetera.   The  survey  must  identify  accurately  the  actual 
useable  shelter  space  available  in  each  structure. 

Stone  and  Webster  uses  a  FEMA  nuclear  attack  value  of 
ten  square  feet  per  person  to  estimate  the  potential 
population  which  can  be  sheltered.   Local  Civil  Defense 
Officials  may  wish  to  allocate  more  space  —  uo  to 
twenty  square  feet  per  person  —  in  their  utilization 
plans.   The  value  used  in  the  survey  overestimates  the 
potential  capacity  of  various  buildings.   We  doubt  that 
17,000  people  can  be  sheltered  at  Ouxbury  High  School, 
or  that  89,700  can  be  sheltered  at  the  5  Cordage  Park 
Buildings. 

The  survey  must  demonstrate  that  public  shelters  are 
free  from  asbestos  and  other  environmental  hazards. 

The  report  estimates  residential  "shelterinq 
capability"  in  individual  communities  as  between  53% 
and  81X.   These  figures  indicate  that  a  significant 
number  of  residents  do  not  have  adequate  domestic 
shelter  and  emphasize  the  need  for  a  full  study  of 
public  shelter  capacities  throughout  the  entire  EPZ, 


429 


Director  Boulay 
Page  3 


Further,  even  if  It  can  be  established  that  the  vast 
majority  of  residences  offer  adeouate  shelter,  local 
officials  must  be  preoared  to  offer  public  shelter  of  a 
known  protective  capability  to  residents  who  demand 
assistance . 

This  report  makes  no  definitive  statement  of  what 
constitutes  adequate  shelter  to  protect  oeoole  from  the 
effects  of  a  radiolooical  release  from  Pilorim 
Station.   This  is  necessary  to  determine  what 
facilities  are  most  appropriate  for  a  local  shelter 
utilization  plan  and  to  determine  the  public  shelter 
needs  of  each  community. 

In  summary,  we  would  say  that  this  survey  is  a  useful  beginning 
but  that  much  more  work  is  required  before  we  can  assess  our 
ability  to  develop  implementable  shelter  utilization  plans 
consistent  with  the  public  safety  concerns  in  Secretary  Barry's 
report  to  the  Governor. 


cc:   Assistant  Secretary  Peter  W.  Agnes,  Jr. 
Deputy  Director  John  L.  Lovering 


430 


BOSTON  EDISON 

itecy  \,e  0*''ces 

800  Scyisto'".  ifee' 

Bailor,  Vassacruse'.tsC2'99 


Ralph  G.  Bird  September  1 7  .  1987 


U.S.  Nuclear  Regulatory  Commission 
Document  Control  Desk 
Washington.  D.C.  20555 

Docket  50-293 
License  No.  DPR-3.'^ 

Subject:  Boston  Edison  Company  Request  for 
Exemption  from  10  CFR  Part  50. 
Appendix  E,  Section  IV. F. 

Dear  Sir: 

In  accordance  with  10  CFR  section  50.12(a).  Boston  Edison  Company  requests 
that  the  Nuclear  Regulatory  Commission  (NRC)  grant  a  one-time  exemption  from 
the  requirements  of  10  CFR  Part  50.  Appendix  E.  Section  IV. F.,  that  would 
authorize  the  next  biennial  full  participation  emergency  preparedness  exercise 
for  the  Pilgrim  Nuclear  Power  Station  (Pilgrim)  to  be  conducted  in  the  second 
quarter  of  1988.  The  schedule  for  future  biennial  exercises  will  not  be 
affected  by  this  one-time  exemption,  but  rather  will  continue  to  provide  that 
such  exercises  will  be  conducted  every  second  year  (i.e..  the  following 
biennial  exercise  will  be  held  in  1989). 

The  proposed  deferral  of  the  full  participation  exercise  has  been  discussed 
with  the  Commonwealth  of  Massachusetts  (Commonwealth)  and  local  emergency 
response  officials.  All  of  the  parties  have  indicated  that  they  support  the 
proposal . 

The  request  will  not  affect  the  onsite  exercise  at  Pilgrim  planned  for 
December  9.  1987. 

The  requested  exemption  is  necessary  because  the  Commonwealth,  the  local 
governments  within  the  ten-mile  plume  exposure  pathway  emergency  planning  zone 
(EPZ)  and  the  two  emergency  reception  center  communities  are  at  present 
engaged  in  implementing  numerous  improvements  in  their  offsite  emergency 
preparedness  programs,  with  the  assistance  of  Boston  Edison.  These 
improvements  include  revision  of  the  emergency  plans  of  the  local  governments 
revision  of  the  Massachusetts  Civil  Defense  Agency  (MCDA)  Area  II  plan  as  well 
as  the  Commonwealth's  state-wide  plan,  the  development  of  revised  related 
procedures  the  development  and  implementation  of  training  programs  for 
officials  and  emergency  personnel,  and  the  upgrading  of  Emergency  Operation 
Centers  (EOC's).  A  substantial  commitment  of  resources  and  time  has  been  made 
to  accomplish,  these  improvements,  and  the  work  is  expected  to  continue  through 
the  remainder  of  the  year  and  early  1988. 


431 


U.S.  Nuclear  Regulatory  Commission 
Page  2 


In  view  of  these  extensive  ongoing  efforts,  the  Commonwealth  and  the  local 
governments  have  indicated  that  they  are  not  able  to  participate  in  an 
exercise  during  calendar  year  1987.  Moreover,  it  is  apparent  that  under  these 
circumstances,  conduct  of  the  full  participation  exercise  will  be  much  more 
effective  after  the  ongoing  improvements  have  been  implemented.  In  granting 
one-time  exemptions  authorizing  deferral  of  exercises  for  licensed  plants  in 
the  past,  the  NRG  has  recognized  that  the  most  effective  and  beneficial 
exercises  are  those  which  include  the  full-scale  participation  of  State  and 
local  governments  and  that  it  is  appropriate  to  defer  an  exercise  until 
program  revisions  or  facility  improvements  have  been  completed. 

Since  the  last  full  participation  biennial  exercise  at  Pilgrim,  Boston  Edison 
has  held  an  onsite  exercise  at  Pilgrim  1n  December  1986;  has  held 
quarterly  onsite  drills  in  March,  Jjne  and  August  of  1987;  and  has  scheduled 
its  annual  onsite  exercise  for  December  9,  1987  (in  which  the  Commonwealth 
will  exercise  various  offsite  objectives  as  described  in  BECo  Ltr.  #87  -147 
"Scheduling  of  Pilgrim  Onsite  Exercise").  The  previous  exercise  and  drills 
have  included  limited  participation  by  the  Commonwealth,  and  the  March  and 
June  1987  drills  included  limited  participation  by  several  of  the  towns.  The 
towns  within  the  EPZ  have  also  cooperated  in  the  full  scale  siren  test 
reviewed  by  FEMA,  which  was  conducted  on  September  29,  1986.  In  addition  to 
its  activities  involving  Pilgrim,  the  Commonwealth  has  also  participated  in 
full  participation  exercises  at  the  Yankee  Nuclear  Power  Station  in  June  1986 
and  is  scheduled  to  participate  In  a  full  participation  exercise  at  the 
Vermont  Yankee  Nuclear  Generating  Station  during  the  week  of  November  29,  1987. 

This  request  meets  a  number  of  the  special  circumstances  listed  In  Section 
50.12(a)(2) 

First,  granting  the  request  will  provide  only  temporary  relief  from  the 
applicable  regulation  and  the  licensee  has  made  good  faith  efforts  to  comply 
with  the  regulation.  Over  the  past  year,  Boston  Edison  has  assisted 
Commonwealth  and  local  authorities  In  a  variety  of  ways  to  accomplish  as  many 
improvements  as  possible  In  their  offsite  emergency  response  programs.  For 
example,  Boston  Edison  has  developed  substantive  Information  for  the 
enhancement  of  those  programs.  The  major  products  of  this  effort  Include  the 
"Pilgrim  Station  Evacuation  Time  Estimates  and  Traffic  Management  Plan  Update" 
(August  18.  1987)  prepared  by  KLD  Associates,  Inc.  and  "A  Study  to  Identify 
Potential  Shelters  In  the  EPZ  Coastline  Region  of  Pilgrim  Nuclear  Power 
Station"  (August  1987)  prepared  by  Stone  &  Webster  Engineering  Corporation,  as 
well  as  Information  generated  In  surveys  to  Identify  the  special  needs  and 
transportation  dependent  populations  within  the  EPZ. 

In  addition.  Boston  Edison  Is  providing  assistance  to  the  local  governments  in 
their  offsite  emergency  program  enhancement  efforts  in  accordance  with  the 
Massachusetts  Civil  Defense  Act  of  1950  (Chapter  639,  Section  15,  Acts  of  1950 
as  amended).  This  assistance  Includes  the  provision  of  two  professional 
planners  to  work  under  the  direction  of  the  officials  of  each  town  within  the 
EPZ  In  upgrading  its  plan,  procedures  and  training;  one 


432 


U.  S.  Nuclear  Regulatory  Commission 
Page  3 


professional  planner  to  assist  each  reception  center  community;  and  four 
professional  planners  working  under  the  direction  of  MCDA  in  the  upgrading  of 
the  MCDA  Area  II  and  Commonwealth  program.  In  the  first  half  of  1987,  Boston 
Edison  provided  introductory  emergency  training  to  about  350  personnel  within 
the  five  towns  in  the  EPZ  and  enhanced  introductory  training  modules  are 
currently  being  prepared  for  review  by  the  MCDA  prior  to  further 
implementation.  The  planners  provided  by  Boston  Edison  have  also  begun  to 
prepare  task-based  modules  for  training  of  specific  categories  of  emergency 
personnel  and  will  be  available  to  participate  in  the  training  programs.  In 
addition.  Boston  Edison  is  executing  agreements  with  each  of  the  five  towns 
within  the  EPZ,  as  well  as  the  two  reception  center  communities,  for 
assistance  in  the  renovation  of  their  EOC's.  Moreover,  four  of  the  five  EPZ 
towns  and  both  reception  center  communities,  to  date,  have  accepted  BECo's 
offer  of  funding  support  for  full-time  civil  defense  staff  positions. 

Second,  literal  compliance  with  the  regulation  would  not  serve  its 
underlying  purpose  and  would  result  in  undue  hardship  to  Commonwealth  and 
local  emergency  response  agencies  by  requiring  an  exercise  of  portions  of  the 
offsite  emergency  plans  that  are  in  the  process  of  significant  revision  and 
improvement.  This  would  necessarily  Involve  disruption  of  the  ongoing  process 
of  implementing  these  changes,  and  consequently,  the  imposition  of  additional 
costs  and  delay  In  accomplishing  the  planned  Improvements.  The  NRC's 
emergency  exercise  requirements  clearly  were  not  Intended  to  disrupt  the    ^ 
orderly  implementation  of  Improvements  in  such  manner. 

Finally,  because  granting  the  request  will  allow  work  to  proceed  without 
disruption,  It  will  result  In  a  net  benefit  to  the  public  health  and  safety. 
The  NRC  has  acknowledged  that  flexibility  Is  appropriate  In  applying  emergency 
planning  requirements.  This  flexible  approach  Is  especially  appropriate  in 
this  case,  where  granting  the  request  will  facilitate  more  prompt  and 
effective  implementation  of  Improvements. 

For  all  these  reasons,  Boston  Edison  asks  that  NRC  grant  the  requested 
exemption.  In  accordance  with  10  CFR  §170. 12(c),  a  fee  of  one  hundred  and 
fifty  dollars  ($150.00)  will  be  electronically  mailed  to  your  offices.  If  you 
should  require  any  additional  Information  In  connection  with  this  request, 
please  contact  either  myself  or  Mr.  Ron  Varley  of  my  staff  (telephone:  617  - 
424-3832). 


ii^4^ 


Ralph  G.  Bird 
RAL/dlw 


433 


U.  S.  Nuclear  Regulatory  Commission 
Page  4 


cc:  Dr.  Thomas  E.  Hurley,  Director 

Office  of  Nuclear  Reactor  Regulation 
U.S.  Nuclear  Regulatory  Commission 
The  Phillips  Building 
Washington.  D.C.  20555 

Mr.  R.H.  Wessman,  Project  Manager 
Division  of  Reactor  Projects  -  I/II 
Office  of  Nuclear  Reactor  Regulation 
U.S.  Nuclear  Regulatory  Commission 
7920  Norfolk.  Avenue 
Bethesda.  MO  20814 

Mr.  Richard  Krimm.  Assistant  Associate  Director 

FEMA 

500  C  Street  -  Federal  Plaza 

Washington,  D.C.  20472 

Mr.  Edward  Thomas 

FEMA  -  Region  1 

J.  W.  McCormack  Post  Office  and  Court  House 

Boston.  MA  02109 

Mr.  Peter  Agnes,  Jr. 
Commonwealth  of  MA 
Assistant  Secretary  of  Public  Safety 
1  Ashburton  Place  -  Room  2133 
Boston.  MA  02108 

U.  S.  Nuclear  Regulatory  Commission 
Region  1  -  631  Park  Avenue 
King  of  Prussia.  PA  19406 

Senior  NRC  Resident  Inspector 
Pilgrim  Nuclear  Power  Station 
Rocky  Hill  Road 
Plymouth.  MA  02360 

Henry  Vickers,  Regional  Director 

FEMA  -  Region  1 

J.W.  McCormack  Post  Office  and  Court  House 

Boston,  MA  02109 


434 

The  Chairman.  Thank  you,  Attorney  General  Shannon.  Glad  to 
see  an  old  friend. 

We'll  move  right  along.  I'm  pleased  to  welcome  the  distinguished 
members  of  our  third  panel,  representing  the  various  branches  in 
state  government  involved  in  the  Pilgrim  restart  question. 

I  remember  the  days  when  the  State  Secretary  of  Energy, 
Sharon  Pollard,  was  a  freshman  legislator;  bright  and  enthusiastic, 
deeply  committed  to  public  service,  now  she  has  moved  onto  higher 
office,  and  I'm  delighted  that  she  has  the  same  enthusiasm  and  is 
an  aggressive  champion  of  the  public  interest  in  the  issues  we've 
been  discussing  this  evening.  I'm  delighted  to  have  her  with  us. 

Ms.  Pollard.  Thank  you.  Senator. 

The  Chairman.  Our  new  Public  Health  Commissioner,  Deborah 
Prothrow-Stith,  and  this  is  her  first  public  appearance  this 
evening,  was  recently  appointed  to  the  position.  Commissioner 
Prothrow-Stith  will  be  discussing  the  important  role  the  Depart- 
ment of  Public  Health  will  play  in  determining  what  public  health 
impacts  are  associated  with  Pilgrim  Power  Plant.  We  are  fortunate 
to  have  had  breakfast  with  the  Reverend  Stith  this  morning,  so 
we've  been  with  the  family  all  day. 

Last,  but  not  least.  Assistant  Secretary  of  Public  Safety,  Peter 
Agnes.  Peter  has  perhaps  the  most  difficult  job  of  all  because  he  is 
trying  to  make  an  unworkable  evacuation  plan  workable.  I'm  look- 
ing forward  to  hearing  from  him.  We'll  start  with  Peter  Agnes,  left 
to  right. 

STATEMENTS  OF  PETER  AGNES,  ASSISTANT  SECRETARY  OF 
PUBLIC  SAFETY;  SHARON  POLLARD,  SECRETARY  OF  STATE  OF 
ENERGY;  AND  DEBORAH  PROTHROW-STITH,  HEALTH  COMMIS- 
SIONER 

Mr.  Agnes.  Thank  you,  Mr.  Chairman.  I'm  here  on  behalf  of  Sec- 
retary Charles  Barry,  who  by  Executive  order  is  the  Disaster  Coor- 
dinator for  the  Commonwealth,  and  also  by  the  Governor's  designa- 
tion, is  the  liaison  officer  for  Massachusetts  to  the  Nuclear  Regula- 
tory Commission,  and  in  that  capacity,  the  Secretary  is  the  princi- 
pal point  of  contact  between  State  officials  and  the  NRC. 

At  the  outset,  I  would  like  to  address  a  point  that  was  made  by 
one  of  the  earlier  speakers,  Ann  Waitkus-Arnold,  concerning  the 
use  of  potassium  iodine,  not  from  a  public  health  standpoint,  which 
the  Commissioner  of  Public  Health  can  do,  but  from  a  planning 
standpoint.  And  I  want  to  correct  a  matter  that  was  referred  to  in 
her  testimony. 

There  is  no  plan  today;  there  has  never  been  to  my  knowledge  a 
plan  in  the  past  and  there  will  never  be  under  the  Dukakis  admin- 
istration, a  plan  that  would  leave  behind  any  member  of  the  com- 
munity, be  they  a  special  needs  person  or  otherwise,  in  the  event  of 
an  evacuation  by  substituting  some  drug,  such  as  potassium  iodine, 
for  the  safe  and  secure  care  of  that  person.  So  no  one  should  be 
misled  into  thinking  that  there  is  any  thought  given  to  leaving 
anyone  behind  during  an  evacuation  who  would  require  attention, 
care  or  evacuation. 

Over  the  past  2  years,  we  have  taken  three  major  actions  to  re- 
spond to  the  health  and  safety  concerns  of  the  Pilgrim  nuclear 


435 

power  plant.  First,  we  have  prepared  and  filed  with  the  Governor 
two  comprehensive  written  reports,  which  other  speakers  here 
have  referred  to,  the  most  recent  of  which  was  released  just  several 
weeks  ago.  And  we  would  like  to  make  those  reports,  which  also 
were  transmitted  to  the  Nuclear  Regulatory  Commission  and  to 
FEMA,  a  part  of  the  record  of  these  proceedings. 

These  reports  deal  at  great  length  with  the  history  of  emergency 
planning  activities,  both  at  the  State  and  Federal  level,  and  with 
the  many  specific  problems  associated  with  the  Pilgrim  plant.  It  is 
our  opinion,  to  paraphrase  the  Federal  Regulatory  Standard,  that 
the  existing  emergency  plans  for  Pilgrim  station  are  not  adequate 
to  protect  the  public  health  and  safety  in  the  event  of  a  radiologi- 
cal emergency  offsite;  and  that,  therefore,  the  plant  should  not  be 
allowed  to  restart  unless  and  until  adequate  plans  are  developed, 
tested  and  approved  by  FEMA  and  the  other  safety  related  con- 
cerns have  been  resolved. 

The  Chairman.  I'm  to  give  you  a  couple  more  minutes. 

Mr.  Agnes.  Thank  you.  Senator.  I  have  said  this  on  many  occa- 
sions and  I  want  to  reiterate  it  tonight,  our  position  has  been  clear 
and  consistent  in  the  past  2  years  on  this  point.  And  one  of  the  un- 
fortunate things  that  we — excuse  me — that  we  are  facing  is  the 
lack  on  the  part  of  the  NRC  a  willingness  to  make  clear  precisely 
what  corrections  or  changes  it  will  insist  upon  in  the  emergency 
plans  before  the  plant  is  restarted. 

The  second  activity  we  have  undertaken  is  to  establish  a  new  di- 
vision in  the  State  within  the  Civil  Defense  Agency  devoted  exclu- 
sively to  nuclear  emergency  preparedness.  Despite  all  of  the  activi- 
ties that  followed  Three  Mile  Island,  at  the  congressional  level  and 
at  the  State  level,  it  is  only  in  the  last  2  years  with  an  initiative 
taken  by  Governor  Dukakis,  that  a  new  division  devoted  exclusive- 
ly to  this  purpose  has  been  established  and  devoted  to  emergency 
planning  problems. 

Third,  for  the  first  time  again,  a  planning  process  has  been  put 
in  place  at  the  State  level,  which  requires  work  on  the  part  of  the 
utility,  local  government  and  State  government  in  an  effort  to  de- 
velop adequate  emergency  plans. 

I  would  like  to  conclude  my  remarks,  Mr.  Chairman,  by  com- 
menting briefly,  but  more  specifically  on  both  the  progress  that  has 
been  made  and  also  the  problems  that  still  remain. 

On  the  progress  side  of  the  ledger,  the  Boston  Edison  Co.  for  the 
first  time  is  a  full  partner  with  State  and  local  officials  in  emergen- 
cy planning.  This  is  evidenced  by  financial  support  the  company 
has  provided  to  local  communities  and  the  fact  that  it  has  assigned 
over  20  people  to  work  in  the  field  with  State  and  local  government 
to  aid  in  the  development  of  draft  plans.  Planning  resources  have 
been  invested  by  the  company  for  the  first  time  to  help  State  and 
local  officials  and  an  inadequate  emergency  communication  system 
that  was  identified  in  our  earlier  report  has  now  been  replaced  by 
the  company. 

The  company  has  produced  several  reports  to  aid  in  the  emergen- 
cy planning  process,  including  a  new  evacuation  time  study  that 
was  given  to  the  Commonwealth  in  the  fall,  and  also  a  study  con- 
cerning the  adequacy  of  relying  upon  only  two,  instead  of  the  previ- 
ous three  reception  centers. 


436 

The  Chairman.  You've  got  30  seconds,  Peter. 

Mr,  Agnes.  On  the  problem  side  of  the  ledger,  we  do  have  some 
severe  problems  that  remain.  We  do  not,  as  I  indicated  earlier, 
have  a  formally  approved  plan  at  this  time.  We  do  not  have  imple- 
menting procedures,  which  are  the  key  part  of  the  plan,  to  help 
deal  with  the  evacuation  and  sheltering  of  special  needs  people  and 
school  children  and  the  infirm  and  the  elderly.  The  shelter  study 
that  has  been  submitted  bv  the  company  is  inadequate  and  we  are 
insistent  that  additional  wt^k  be  done. 

The  reception  center  study  that  we  just  recently  received  and 
which  is  of  great  concern  to  residents  here  in  the  Plymouth  area, 
while  useful,  is  not  sufficient  in  our  opinion,  and  we  have  deter- 
mined that  a  third  reception  center  for  the  Pilgrim  plant  must  be 
sited  and  we  will  make  a  decision  in  that  regard  as  to  a  new  site 
very  shortly. 

In  conclusion,  I  would  like  to  say  that  on  balance,  our  diagnosis 
is  that  while  the  patient  has  improved;  it  remains  quite  ill  and  the 
prognosis  is  very  uncertain.  It  remains  to  be  seen,  in  our  judgment, 
whether  or  not  adequate  emergency  plans  for  the  Pilgrim  nuclear 
power  plant  can  be  developed,  and  as  many  of  the  speakers  here 
before  have  indicated  the  only  way  to  insure  that  the  issues  that 
we  have  identified  are  aired  totally  and  fairly  is  to  hold  an  adjudi- 
catory hearing  before  restart.  Thank  you,  Mr.  Chairman. 

[The  prepared  statement  of  Mr.  Agnes  follows:] 


437 


Michael  S.  Dukakis 

Governor 

Charles  V.  Barry 
Secretary 


^oA/bn,  .JLAAacAuAelt^0?y08  f'SflJ  7f7 -7775 


TESTIMONY  OF  PETER  W.  AGNES,  JR. 

ASSISTANT  SECRETARY  OF  PUBLIC  SAFETY 

JANUARY  1,     1988 

GOOD  EVENING  MR.  CHAIRMAN  AND  MEMBERS  OF  THE  COMMITTEE.   I 

AM  HERE  ON  BEHALF  OF  SECRETARY  CHARLES  V.  BARRY  WHO  BY 

EXECUTIVE  ORDER  IS  THE  DISASTER  COORDINATOR  FOR  THE  STATE  AND 

BY  DESIGNATION  OF  THE  GOVERNOR  IS  THE  LIAISON  OFFICER  FOR 

MASSACHUSETTS  TO  THE  NUCLEAR  REGULATORY  COMMISSION.   IN  THE 

LATTER  CAPACITY,  THE  SECRETARY  IS  THE  PRINCIPAL  POINT  OF 

CONTACT  BETWEEN  STATE  OFFICIALS  AND  THE  N.R.C. 

THE  EXECUTIVE  OFFICE  OF  PUBLIC  SAFETY  SUPERINTENDS  TWO 
STATE  AGENCIES  WITH  RESPONSIBILITY  IN  THIS  AREA— THE  DEPARTMENT 
OF  PUBLIC  SAFETY  WHICH  LICENSES  NUCLEAR  POWER  PLANT  OPERATORS 
AND  THE  CIVIL  DEFENSE  AGENCY  WHICH  IS  RESPONSIBLE  FOR  PREPARING 
AND  UPDATING  EMREGENCY  PLANS.   MOREOVER,  OTHER  AGENCIES  AND 
DIVISIONS  WITHIN  OUR  SECRETARIAT  WOULD  PLAY  A  VITAL  ROLE  IN 
RESPONDING  TO  ANY  EMERGENCY  AT  A  NUCLEAR  POWER  PLANT  WHERE 
THERE  WAS  A  PUBLIC  HEALTH  OR  SAFETY  IMPACT  OUTSIDE  THE  PLANT. 

OVER  THE  PAST  TWO  YEARS,  WE'VE  TAKEN  THREE  MAJOR  ACTIONS  TO 
RESPOND  TO  THE  HEALTH  AND  SAFETY  CONCERNS  AT  THE  PILGRIM  PLANT. 

FIRST,  WE  HAVE  PREPARED  AND  FILED  WITH  THE  GOVERNOR  TWO 
COMPREHENSIVE  WRITTEN  REPORTS,  THE  MOST  RECENT  OF  WHICH  WAS 


438 


TESTIMONY  OF  PETER  W.  AGNES,  JR. 
ASSISTANT  SECRETARY  OF  PUBLIC  SAFETY 
PAGE  TWO 

RELEASED  JUST  SEVERAL  WEEKS  AGO.   I  WOULD  LIKE  TO  MAKE  THESE 
REPORTS  PART  OF  THE  RECORD.   THESE  REPORTS  DEAL  AT  LENGTH  WITH 
THE  HISTORY  OF  EMERGENCY  PLANNING  ACTIVITIES  AT  THE  STATE  AND 
FEDERAL  LEVEL  AND  WITH  THE  SPECIFIC  PROBLEMS  ASSOCIATED  WITH 
THE  PILGRIM  PLANT.   IT  IS  OUR  OPINION,  TO  PARAPHRASE  THE 
FEDERAL  REGULATORY  STANDARD,  THAT  EXISTING  EMERGENCY  PLANS  FOR 
PILGRIM  STATION  ARE  NOT  ADEQUATE  TO  PROTECT  THE  PUBLIC  HEALTH 
AND  SAFETY  IN  THE  EVENT  OF  A  RADIOLOGICAL  EMERGENCY  OFFSITE  AND 
THAT  THE  PLANT  SHOULD  NOT  BE  ALLOWED  TO  RESTART  UNLESS  AND 
UNTIL  ADEQUATE  PLANS  ARE  DEVELOPED,  TESTED  AND  APPROVED  BY 
FEMA,  AND  THE  OTHER  SAFETY  RELATED  CONCERNS  HAVE  BEEN  RESOLVED. 

SECOND,  WE  HAVE  ESTABLISHED  A  NEW  DIVISION  WITHIN  THE  CIVIL 
DEFENSE  ACENCY  WITH  FISCAL  OVESIGHT  WITHIN  EOPS  DEVOTED 
EXCLUSIVEL/  TO  NUCLEAR  EMERGENCY  PREPAREDNESS.   THIS  DIVISION 
IS  TAKING  A  LEADERSHIP  ROLE  WITH  LOCAL  OFFICIALS  AND  UTILITY 
EMPLOYEES  TO  INSURE  THAT,  UNLIKE  IN  THE  PAST,  THERE  IS  ONLY  ONE 
PLANNING  PROCESS  UNDER  STATE  SUPERVISION. 

THIRD,  WE  HAVE  ESTABLISHED  A  FORMAL  PLANNING  PROCESS  TO 
CARRY  OUT  THE  RESPONSIBILITIES  ASSIGNED  TO  US  UNDER  STATE  LAW. 
THE  PROCESS  INVOLVES  THE  UTILITY,  COMMUNITY  GROUPS,  AND  LOCAL 
AND  STATE  OFFICIALS  MEETING  TOGETHER  REGULARLY  TO  ADDRESS 
EMERGENCY  PREPAREDNESS  ISSUES.   IN  DOING  SO  WE  HAVE  BEEN 
CAREFUL  TO  UNDERTAKE  THIS  PROCESS  ON  BEHALF  OF  THE  THREE 
LICENSED  PLANTS  THAT  AFFECT  MASSACHUSETTS--PILGRIM,  ROWE ,  AND 
VERNON — AT  THE  SAME  TIME  THAT  WE  CONTINUE  TO  ABIDE  BY  THE 
STATE'S  POLICY  THAT  THERE  SHALL  BE  NO  PLANNING  FOR  THE  SEABROOK 
PLANT. 


439 


TESTIMONY  OF  PETER  W.  AGNES,  JR. 
ASSISTANT  SECRETARY  OF  PUBLIC  SAFETY 
PAGE  THREE 

I  WOULD  LIKE  TO  CONCLUDE  MY  REMARKS  BY  COMMENTING  BRIEFLY, 
BUT  MORE  SPECIFICALLY  ON  SOME  OF  THE  PROGRESS  WE  HAVE  MADE  AND 
PROBLEMS  THAT  STILL  REMAIN. 

ON  THE  PROGRESS  SIDE  OF  THE  LEDGER  THE  BOSTON  EDISON 
COMPANY,  FOR  THE  FIRST  TIME,  IS  A  FULL  PARTNER  WITH  STATE  AND 
LOCAL  OFFICIALS  IN  THE  EMERGENCY  PLANNING  EFFORT.   THE  UTILITY 
IS  INVESTING  IN  THE  PLANNING  RESOURCES  REQUIRED  BY  LOCAL  AND 
STATE  OFFICIALS.   THE  UTILIITY  HAS  REPLACED  AN  INADEQUATE 
EMERGENCY  COMMUNICATIONS  SYSTEM  WITH  A  MUCH  MORE  SOPHISTICATED 
AND  ENLARGED  SYSTEM.   THE  UTILTY  HAS  ASSIGNED  MORE  THAN  TWENTY 
PERSONS  TO  WORK  WITH  STATE  AND  LOCAL  OFFICIALS  AND  HAS  AIDED  IN 
THE  DEVELOPMENT  OF  DRAFT  EMERGENCY  PLANS  WHICH  ARE  CURENTLY 
BEING  REVIEWED  BY  LOCAL  OFFICIALS.   THE  UTILITY  HAS  PRODUCED  A 
NEW  EVACUATION  TIME  ESTIMATE  STUDY  THAT  WE  RECEIVED  DURING  THE 
SUMMER  AND  HAS  JUST  PROVIDED  US  WITH  A  STUDY  ON  THE  ADEQUACY  OF 
USING  ONLY  THE  TWO  EXISTING  RECEPTION  CENTERS  FOR  THE  EPZ . 
FINALLY  THE  UTILITY  HAS  MADE  MAJOR  CHANGES  IN  THE  MANAGEMENT  OF 
ITS  NUCLEAR  OPERATION  AND  INVESTED  HEAVILY  IN  AN  ON-SITE  SAFETY 
ENHANCEMENT  PROGRAM.   ALSO,  IT  SHOULD  BE  NOTED  THAT  SPECIAL 
TASK  FORCES  HAVE  BEEN  ESTABLISHED  TO  ADDRESS  THE  SPECIAL  NEEDS 
ISSUES  AND  TO  RECOMMEND  IMPROVEMENTS  IN  THE  EMERGENCY  PUBLIC 
INFORMATION  MATERIAL  THAT  IS  DISTRIBUTED  ANNUALLY .THESE  ARE 
SIGNIFICANT  AND  POSITIVE  DEVELOPMENTS. 


440 


TESTIMONY  OF  PETER  W.  AGNES,  JR. 
ASSISTANT  SECRETARY  OF  PUBLIC  SAFETY 
PAGE  FOUR 

SIMILARLY,  LOCAL  OFFICIALS  AND  COMMUNITY  GROUPS  HAVE  BEEN 

WORKING  CLOSELY  WITH  THE  STAFF  OF  THE  NEW  DIVISION  OF  NUCLEAR 

EMERGENCY  SAFETY  WITHIN  CIVIL  DEFENSE  IN  AN  EFFORT  TO  DEVELOP 

THE  BEST  POSSIBLE  EMERGENCY  EVACUATION  PLANS.   IN  MANY  CASES, 

THIS  EFFORT  HAS  MEANT  THAT  LOCAL  AND  STATE  OFFICIALS  HAVE 

WORKED  NIGHTS  AND  WEEKENDS  WITHOUT  COMPENSATION. 

ON  THE  PROBLEM  SIDE  OF  THE  LEDGER,  WE  DO  NOT  YET  HAVE  A 

FORMALLY  APPROVED  EMERGENCY  PLAN  TO  RESPOND  TO  AN  ACCIDENT  AT 

PILGRIM  STATION  AND  IT  REMAINS  TO  BE  SEEN  WHETHER  AN  ADEQUATE 

PLAN  CAN  BE  DEVELOPED.   THE  MOST  IMPORTANT  AND  DIFFICULT  PART 

OF  THE  EMERGENCY  PLANS — THE  DEVELOPMENT  OF  IMPLEMENTING 

PROCEDURES  FOR  PERSONS  WITH  SPECIAL  NEEDS  (SCHOOL  CHILDREN,  THE 

HANDICAPPED,  THE  INFIRM  ETC.) — DO  NOT  YET  EXIST  EVEN  IN  DRAFT 

FORM.   QUESTIONS  HAVE  BEEN  RAISED  ABOUT  THE  VALIDITY  OF  THE 

EVACUATION  TIME  ESTIMATES  ANS  WE  HAVE  DECIDED  TO  SUBMIT  IT  FOR 

AN  OUTSIDE  EVALUATION.   THE  SHELTERING  STUDY  PREPARED  BY  BECO. 

EARLIER  IN  THE  YEAR  IS  INADEQUATE  AND  IT  REMAINS  TO  BE  SEEN  IF 

THERE  IS  ADEQUATE  SHELTER  FOR  THE  POPULATION.   A  SURVEY  OF 

PERSONS  WITH  SPECIAL  NEEDS  WAS  PREPARED  BY  BECO.  EARLIER  IN  THE 

YEAR  WITHOUT  STATE  OR  LOCAL  PARTICIPATION  OR  APPROVAL  AND  IS 

INADEQUATE.   THE  RECEPTION  CENTER  STUDY  WE  RECEIVED  TWO  WEEKS 

AGO  IS  USEFUL,  BUT  WE  HAVE  CONCLUDED  THAT  A  THIRD  RECEPTION 

CENTER  FOR  THE  NORTHERN  EPZ  RESIDENTS  IS  NECESSARY.   WE  WILL 

DESIGNATE  A  SITE  IN  A  SHORT  WHILE. 

IN  TERMS  OF  ON-SITE  ACTIVITITES,  WE  ARE  TROUBLED  BY  THE 

DECISION  OF  THE  N.R.C.  TO  LEAVE  UNRESOLVED  THE  SAFETY  ISSUES 


441 

TESTIMONY  OF  PETER  W.  AGNES,  JR. 
ASSISTANT  SECRETARY  OF  PUBLIC  SAFETY 
PAGE  FIVE 

PRESENTED  BY  BOSTON  EDISON  COMPANY'S  PROPOSAL  TO  INSTALL  A 
DIRECT  TORUS  VENT  TO  MITIGATE  THE  CONSEQUENCES  OF  CERTAIN  KINDS 
OF  ACCIDENTS  INVOLVING  THE  MARK  ONE  CONTAINMENT.   THE  EDISON 
INITIATIVE  WAS  TAKEN  IN  RESPONSE  TO  AN  N.R.C.  STAFF 
RECOMMENDATION.   IN  AUGUST,  1987,  DR.  TOM  MURLEY  WROTE  TO 
BECO.AND  ADVISED  THEM  THAT  HE  WAS  NOT  PREPARED  TO  APPROVE  THE 
DIRECT  VENT  PROPOSAL  WITHOUT  FURTHER  INFORMATION.   TO  OUR 
KNOWLLEDGE,  BECO .  HAS  NOT  SUBMITTED  ITS  RESPONSE.   THIS  IS  JUST 
ONE  REASON  WHY  OUR  CALL  UPON  EDISON  TO  PRODUCE  THE 
PROBABALISTIC  RISK  ANALYSIS  WE  BELIEVE  HAS  BEEN  PREPARED  IS  SO 
IMPORTANT. 

MANAGEMENT  CONCERNS  ALSO  CONTINUE  TO  EXIST  AT  PILGRIM.   THE 
MOST  RECENT  SYSTEMATIC  ASSESSMENT  OF  LICENSEE  PERFORMANCE 
REPORT  (SALP)  INDICATES  THAT  BECO.  SCORED  LOW  IN  A  NUMBER  OF 
SAFETY  RELATED  CATEGORIES.   IN  AUGUST,  SECURITY  VIOLATIONS 
OCCURRED  AT  THE  PLANT  THAT  ARE  THE  SUBJECT  OF  AN  ONGOING  N.R.C. 
INVESTIGATION.   A  LOSS  OF  POWER  INCIDENT  ON  NOVEMBER  12,  1987 
WAS  THE  SUBJECT  OF  A  RECENT  AUGMENTED  INSPECTION  REPORT. 
ALTHOUGH  NO  VIOLATION  OF  REGULATORY  REQUIREMENTS  WAS  FOUND,  THE 
REPORT  CRITICIZES  THE  OVERALL  MANAGEMENT  OF  THE  RECOVERY  AND 
FOUND  PLANNING  WEAKNESS. 


442 


TESTIMONY  OF  PETER  W.  AGNES,  JR. 
ASSISTANT  SECRETARY  OF  PUBLIC  SAFETY 
PAGE  SIX 

ON  BALANCE,  MY  DIAGNOSIS  IS  THAT  THE  PATIENT  HAS  IMPROVED 
BUT  REMAINS  QUITE  ILL  AND  THE  PROGNOSIS  IS  UNCERTAIN. 

FOR  THESE  REASONS,  IT  IS  IMPERATIVE,  IN  OUR  JUDGMENT,  THAT 
THE  N.R.C.  HEED  THE  CALL  BY  GOVERNOR  DUKAKIS  AND  ATTORNEY 
GENERAL  SHANNON  TO  CONDUCT  AN  ADJUDICATORY  HEARING  BEFORE 
CONSIDERING  ANY  REQUEST  TO  RESTART  THE  PILGRIM  PLANT. 

I  WOULD  BE  HAPPY  TO  TAKE  ANY  QUESTIONS. 

RESPECTFULLY  SUBMITTED 


Peter  W.  Agnes,  Jr. 
Assistant  Secretary 


443 

The  Chairman.  Thank  you.  Sharon  Pollard. 

Ms.  Pollard.  Thank  you,  Senator.  It  is  nice  to  be  here,  and  I  as 
well  would  like  to  thank  you  for  holding  this  hearing  on  a  subject 
so  important  to  not  only  the  people  in  and  around  Plymouth  area, 
but  certainly  to  all  the  people  of  Massachusetts. 

You've  asked  for  me  this  evening  to  speak  about  the  demand  for 
Pilgrim's  power  in  meeting  Massachusetts'  and  New  England's 
energy  situation.  While  the  current  supply  in  the  Commonwealth 
of  Massachusetts  of  energy  is  tight,  it  is  not  so  tight  that  the  public 
health  and  safety  need  be  placed  at  risk  with  the  operation  of  any 
given  power  plants,  including  the  Pilgrim  nuclear  power  plant. 

New  analyses  prepared  by  the  New  England  Governors'  Confer- 
ence and  the  New  England  Energy  Policy  have  indicated  that  New 
England's  power  needs  can  be  met  with  existing  and  planned  re- 
sources and  potential  new  resources  combined  with  effective  man- 
agement. These  analyses  have  provided  evidence  that  Pilgrim  will 
not  make  or  break  the  electricity  supply  of  New  England. 

In  Massachusetts,  State  and  utility  officials  are  working  to 
assure  that  power  will  be  available  when  needed  and  at  a  reasona- 
ble cost,  both  over  the  short  term  and  the  long  term. 

Recent  accomplishments  of  State  and  utility  officials  will  im- 
prove the  power  supply  of  the  region.  For  example,  the  enactment 
of  the  State  appliance  efficiency  standards  last  year;  a  more  effi- 
cient building  code,  so  that  the  buildings  we  construct  in  Massa- 
chusetts could  be  ones  that  could  use  energy  efficiently.  The  estab- 
lishment of  a  cogeneration  of  small  power  bidding  and  development 
process,  and  the  approval  by  the  Energy  Facility  Siting  Council,  of 
which  I  chaired  a  couple  of  weeks  ago,  of  a  300  megawatt  gas  unit 
in  Bellingham,  MA.  These  will  make  substantial  contributions  to 
the  Massachusetts  electricity  need. 

In  addition,  current  projects  will  enhance  future  power  planning 
and  supply.  For  example,  State  officials  have  requested  utilities  to 
increase  their  capabilities  to  manage  load  requirements  at  the  time 
of  peak  demand.  The  State  is  also  investing  ways  to  fully  develop 
conservation,  load  management  and  cogeneration  at  State  facilities. 
Furthermore,  the  Executive  Office  of  Energy  Resource  and  others 
are  working  with  the  Department  of  Public  Utilities  to  establish 
least-cost  planning  process,  which  will  significantly  enhance  the  de- 
velopment of  cost  effective,  socially  beneficial  electric  resources  in 
Massachusetts. 

What  I  would  also  like  to  note  is  that  Pilgrim's  past  operating 
performance  indicates  that  it  cannot  necessarily  be  relied  upon  to 
provide  the  power  that  we  need.  Pilgrim's  lifetime  operating  per- 
formance is  worse  than  roughly  80  percent  of  all  the  other  nuclear 
power  plants  in  the  country.  In  the  past.  Pilgrim  has  been  avail- 
able to  produce  electricity  less  than  half  of  the  time  that  it  was 
needed. 

In  addition,  there  is  not  a  strong  need  to  operate  Pilgrim  for  eco- 
nomic reasons.  While  there  are  many  uncertainties  as  to  the  eco- 
nomics of  future  power  supplies,  a  recent  analysis  indicates  that 
Pilgrim  may  not  necessarily  provide  any  economic  savings  to  rate- 
payers if  it  operates. 

"Therefore,  I  would  like  to  make  it  clear  that  while  peak  electrici- 
ty resources  are  currently  tight,  there  is  no  compelling  need  to  op- 


444 

erate  Pilgrim  for  power  supply  or  econc^nic  purposes  if  it  poses  an 
unacceptable  risk  to  the  health  and  safety  of  the  people  of  Massa- 
chusetts. 

As  was  indicated  by  my  colleagues  from  the  administration,  Gov- 
ernor Dukakis  has  not  yet  made  a  determination  as  to  the  ultimate 
role  which  he  believes  Pilgrim  should  play,  if  any.  The  determina- 
tion will  be  made  only  after  the  issues  of  plant  management,  con- 
tainment integrity  and  evacuation  plan  adequacy  have  been  re- 
solved. Thank  you  very  much,  Senator. 

The  Chairman.  Thank  you  very  much.  Dr.  Prothrow-Stith. 

Dr.  Prothrow-Stith.  Good  evening.  Senator.  Let  me  start  by 
adding  my  thanks  to  you  for  this  opportunity.  I  represent  Secretary 
Johnston  of  the  Executive  Office  of  Human  Services  and  the  De- 
partment of  Public  Health  as  its  commissioner. 

We  take  seriously  our  responsibilities  for  the  health  of  the  citi- 
zens of  Massachusetts,  and  with  regard  to  the  Pilgrim  plant  we 
have  two  responsibilities.  One  has  to  do  with  monitoring  radiation 
exposure,  and  the  other  one  has  to  do  with  investigation  of  disease 
outbreaks. 

Relative  to  monitoring,  we  are  the  primary  State  agency  respon- 
sible for  radiation  control.  We  have  conducted  radiation  monitoring 
activities  in  the  vicinity  of  the  plant  since  the  mid  1970's.  These 
activities  include:  one,  a  network  of  monitoring  stations;  two,  peri- 
odic surveys  to  determine  the  extent  and  seriousness  of  radiation 
dosage  received  by  humans  and  animals;  and,  three,  periodic  in- 
spections of  the  power  plants  itself. 

Our  monitoring  of  radiation  includes  the  dosimeters  located  at  46 
sites  to  measure  radiation.  They  are  tested  quarterly  and  would  in- 
dicate any  unusual  exposure  to  radiation  among  the  population 
within  5  miles  of  the  reactor.  We  also  monitor  airborne  radiation 
at  the  plant.  Water,  milk,  food,  fish,  and  sediment  samples  are  also 
tested  regularly.  We  conduct  weekly  inspections  of  the  Pilgrim 
plant,  checking  internal  monitoring  and  safety  protocol.  In  the 
event  of  an  accident,  we  would  be  responsible  for  a  dose  assessment 
and  for  recommendations  of  appropriate  protective  actions. 

The  department  wants  to  establish  a  state  of  the  art  comprehen- 
sive monitoring  program  in  the  vicinity  of  Pilgrim  that  could  serve 
as  an  early  notification  system  and  insure  prompt  emergency  re- 
sponse in  the  event  of  any  releases  of  radioactivity  that  might 
present  a  threat  to  the  public  health  and  safety,  and  also  to  insure 
adequate  monitoring  points  to  measure  radiation  in  the  vicinity  of 
the  reactor. 

The  department  wants  a  real  time  monitoring  system  which 
would  involve  the  transmission  to  a  State  facility  of  ongoing  radi- 
ation levels  at  selected  locations  both  within  the  boundaries  and 
offsite  of  the  nuclear  powerplants.  This  system,  similar  to  one  in 
place  in  Illinois,  would  allow  the  department  to  know  instanta- 
neously when  radiation  was  released  into  the  environment.  In  addi- 
tion, an  on-line  data  communication  link  to  the  state's  facilities 
computer  would  be  included  in  this  system.  This  would  allow  us  to 
know  the  status  of  the  reactor,  that  is,  the  temperature,  the  pres- 
sure, the  water  level,  et  cetera,  on  a  real  time  basis,  as  well  as  fur- 
ther provide  early  notification  of  events  that  could  lead  to  nuclear 


445 

accidents.  We  believe  that  this  improved  monitoring  is  an  impor- 
tant part  of  a  safe  evacuation  plan. 

Our  second  responsibility  is  the  investigation  of  disease  out- 
breaks. 

The  Chairman.  Let  me  ask  you  about  that  monitoring  program. 
That  is  going  to  cost  something,  I  imagine? 

Dr.  Prothrow-Stith.  It  will  cost  something. 

The  Chairman.  Is  that  going  to  be  a  priority  for  the  state  or  are 
you  going  to  the  Federal  Government  or  what? 

Dr.  Prothrow-Stith.  This  is  something  that  at  this  point,  we  are 
proposing;  it  has  been  proposed  in  the  past  and  we  are  in  the  very 
early  stages  of  a  more  recent  proposal. 

The  Chairman.  Does  Illinois  pay  for  it  out  of  State  funds  or  do 
they  get  some  Federal  funding,  do  you  know? 

Dr.  Prothrow-Stith.  I'm  not  sure. 

The  Chairman.  OK.  Well,  if  you  might  let  us  know  on  that.  If  it 
is  done  with  the  States'  funds,  obviously  we'll  welcome  that.  If  you 
feel  you  have  to  come  to  the  Federal  Government,  I'll  be  glad  to 
submit 

Dr.  Prothrow-Stith.  An  offer  that  we  would  appreciate.  [Laugh- 
ter.] 

The  Chairman.  We'll  stop  right  now,  and  I'll  ask  you  to  stand,  if 
you  would.  [Laughter.] 

Listen  carefully. 

[Witnesses  sworn.] 

Do  you  solemnly  swear  that  the  testimony  you  have  given  and  will  continue  to 
give  will  be  the  truth,  the  whole  truth,  and  nothing  but  the  truth,  so  help  you  God? 

The  Chairman.  Three  years  of  law  school.  Well,  that  is  a  serious 
matter.  As  you  mentioned,  the  work  that  is  done  in  Illinois  appears 
to  be  important  and  significant,  and  we'd  like  to  know  how  it  is 
going  to  proceed  and  hope  you  keep  in  touch. 

Dr.  Prothrow-Stith.  We  would  like  to  do  that. 

Relative  to  the  investigation  of  disease  outbreaks  that  might  be 
caused  by  contamination  in  the  environment,  we  are  currently  con- 
ducting a  study  in  the  Plymouth  area  into  the  causes  of  elevated 
rates  of  leukemia,  a  type  of  cancer  that  is  shown  to  be  caused  by 
ionizing  radiation. 

We  concluded  an  assessment  of  the  1982  to  1985  health  related 
data  for  the  area  around  the  plant  in  order  to  determine  the  health 
of  South  Shore  residents  and  how  that  might  be  affected  by  the  Pil- 
grim reactor.  That  assessment  showed  no  unusual  statistical  trends 
in  the  patterns  of  death  from  cancer  or  in  the  frequency  of  infant 
mortality.  Some  anomalies  in  infant  mortality  and  low  birth  rates 
had  been  reported.  The  numbers  are  so  small  that  it's  impossible  to 
draw  any  statistically  valid  conclusion. 

We  did  find,  however,  a  statistically  significant  excess  in  the  inci- 
dents of  leukemia  among  males  in  the  five  coastal  communities 
surveyed.  These  elevations  are  specifically  among  the  types  of  leu- 
kemia that  can  be  caused  by  exposure  to  radiation. 

The  incidents  of  leukemia  am.ong  females  was  also  elevated,  but 
not  to  the  same  significant  degree.  The  group  should  question,  of 
course,  whether  Pilgrim  is  responsible  for  the  high  incidents  of  leu- 
kemia. At  present  it  is  impossible  to  answer  that  question,  but  the 


446 

Department  of  Public  Health  is  currently  conducting  two  separate 
investigations  that  may  bring  us  closer  to  the  answer. 

First,  we  are  conducting  a  case-control  epidemiological  study  to 
help  us  identify  the  possible  causes  of  the  excess  leukemia.  In  the 
course  of  this  study,  we  will  interview  all  leukemia  cases  diagnosed 
since  1982,  or  their  families,  in  the  communities  of  Plymouth, 
Kingston,  Duxbury,  Marshfield,  and  Scituate.  We'll  take  data  on 
the  places  of  residence,  occupation  and  medical  histories.  This  in- 
formation will  be  compared  with  similar  data  from  people  without 
leukemia  from  the  same  communities  in  order  to  look  for  any  dif- 
ferences. This  study  will  help  determine  any  association  between 
leukemia  and  possible  other  sources  of  exposure,  such  as  Benzene, 
chemotherapy,  et  cetera. 

We  must  be  very  frank  about  the  limitations  of  this  study.  Epide- 
miology has  its  limits,  especially  in  cases  where  we  are  dealing 
with  small  populations,  relatively  small  number  of  cases,  small 
doses  and  small  levels  of  exposure,  but  if  we  don't  look,  we  won't 
learn  an5^hing  at  all. 

Second,  we're  looking  into  the  possibilities  that  a  coastal  wind 
pattern  may  have  contributed  to  the  dispersion  of  radiation  emis- 
sion from  Pilgrim  in  a  way  that  bypassed  existing  radiation  moni- 
toring. This  work,  being  conducted  through  a  contract  at  the  Har- 
vard School  of  Public  Health,  will  determine  the  feasibility  of  esti- 
mating the  level  of  radiation  reaching  the  general  population.  This 
study  is  up  and  running  and  should  be  completed  within  the  next 
couple  of  months  in  its  initial  phase. 

It  is  our  objective  that  the  combined  results  of  these  investiga- 
tions will  permit  an  informed  estimate  of  the  contributions  of  Pil- 
grim emissions  to  the  elevated  incidence  of  leukemia  in  the  vicinity 
of  Pilgrim.  We  would  like  to  work  with  Dr.  Winegarten,  if,  in  fact, 
NIH  is  very  interested  in  doing  some  work  here.  We  would  be  ex- 
cited about  that  opportunity. 

In  summary,  we  are  interested  in  increasing  our  monitoring  ca- 
pabilities so  that  you  have  state  of  the  art  capability,  and  also  we 
are  very  interested  in  continuing  these  studies,  but  as  well,  partici- 
pating with  NIH  if  that  opportunity  is  available.  Thank  you  very 
much. 

[The  prepared  statement  of  Dr.  Prothrow-Stith  follows:] 


447 


^.-s^y- 


Mlchaal  S.  Dukakis 
Govamor 

Philip  W.  Johnston 
Sac  rata  ry 


150  /Ttv-fTUim/  J^tive/ 

6'/7-7S7-S700 


'^'~™CommlM'I^n,r'**°TESTIMONY  OF  DEBORAH  PROTHROW-STITH ,  M.D. 
COMMISSIONER,  DEPARTMENT  OF  PUBLIC  HEALTH 
JANUARY  7,  1988 

GOOD  EVENING  MR.  CHAIRMAN  AND  MEMBERS  OF  THE 
COMMITTEE.   MY  NAME  IS  DEBORAH  PROTHROW-STITH  AND 
I  AM  COMMISSIONER  OF  THE  DEPARTMENT  OF  PUBLIC 
HEALTH. 

THE  MASSACHUSETTS  DEPARTMENT  OF  PUBLIC  HEALTH 
HAS  A  TWO-FOLD  RESPONSIBILITY  WITH  RESPECT  TO  THE 
OPERATIONS  OF  THE  PILGRIM  NUCLEAR  POWER  PLANT, 
MONITORING  RADIATION  EXPOSURE  AND  INVESTIGATING 
DISEASE  OUTBREAKS. 


-FIRST,  WE  ARE  THE  PRIMARY  STATE  AGENCY 
RESPONSIBLE  FOR  RADIATION  CONTROL.   WE  HAVE 
CONDUCTED  EXTENSIVE  RADIATION  MONITORING 
ACTIVITIES  IN  THE  VICINITY  OF  THE  PLANT  SINCE  THE 
MID-1970S.   THESE  ACTIVITIES  INCLUDE  A  NETWORK  OF 
MONITORING  STATIONS,  PERIODIC  SURVEYS  TO 
DETERMINE  THE  EXTENT  AND  SERIOUSNESS  OF  RADIATION 
DOSES  RECEIVED  BY  HUMANS  AND  ANIMALS  AND  PERIODIC 
INSPECTIONS  OF  THE  POWER  PLANT  ITSELF. 


448 


-2- 

OUR  MONITORING  OF  RADIATION  INCLUDES 
DOSIMETERS  LOCATED  AT  46  SITES  TO  MEASURE  GAMMA 
RADIATION,  THE  TYPE  OF  RADIATION  WE  WOULD  FIND. 
THESE  DOSIMETERS  ARE  CHECKED  QUARTERLY,  AND  THEY 
WOULD  INDICATE  ANY  UNUSUAL  EXPOSURE  TO  GAMMA 
RADIATION  AMONG  THE  POPULATION  WITHIN  FIVE  MILES 
OF  THE  REACTOR. 

THROUGH  A  COOPERATIVE  AGREEMENT  WITH  THE 
NUCLEAR  REGULATORY  COMMISSION,  WE  CONTINUALLY 
MONITOR  AIRBORNE  RADIATION  AT  THE  PLANT.   WATER, 
MILK,  FOOD,  FISH,  AND  SEDIMENT  SAMPLES  ARE  TESTED 
REGULARLY.   WE  ALSO  CONDUCT  WEEKLY  INSPECTIONS  OF 
THE  PILGRIM  PLANT,  CHECKING  INTERNAL  MONITORING 
AND  SAFETY  PROTOCOLS. 

IN  THE  EVENT  OF  AN  ACCIDENT,  THE  DEPARTMENT 
OF  PUBLIC  HEALTH  WOULD  BE  RESPONSIBLE  FOR  DOSE 
ASSESSMENT  AND  FOR  RECOMMENDING  APPROPRIATE 
PROTECTIVE  ACTIONS. 

THE  DEPARTMENT  WANTS  TO  ESTABLISH  A  STATE  OF 
THE  ART  COMPREHENSIVE  MONITORING  PROGRAM  IN  THE 
VICINITY  OF  PILGRIM  THAT  COULD  SERVE  AS  AN  EARLY 
NOTIFICATION  SYSTEM  AND  INSURE  PROMPT  EMERGENCY 
RESPONSE  IN  THE  EVENT  OF  ANY  RELEASES  OF 
RADIOACTIVITY  THAT  MIGHT  PRESENT  A  THREAT  TO 


449 


-3- 
PUBLIC  HEALTH  AND  SAFETY  AND  ALSO  TO  INSURE 
ADEQUATE  MONITORING  POINTS  TO  MEASURE  RADIATION 
IN  THE  VICINITY  OF  THE  REACTOR. 

THE  DEPARTMENT  ALSO  WANTS  A  REAL  TIME 
MONITORING  SYSTEM  WHICH  WOULD  INVOLVE  THE 
TRANSMISSION  TO  A  STATE  FACILITY  OF  ONGOING 
RADIATION  LEVELS  AT  SELECTED  LOCATIONS  BOTH 
WITHIN  THE  BOUNDARIES  AND  OFF-SITE  OF  NUCLEAR 
POWER  PLANTS.    THIS  SYSTEM  WOULD  ALLOW  THE 
DEPARTMENT  TO  KNOW  INSTANTANEOUSLY  WHEN  RADIATION 
WAS  RELEASED  INTO  THE  ENVIRONMENT.    IN  ADDITION, 
AN  ON-LINE  REACTOR  PARAMETER  DATA  COMMUNICATION 
LINK  TO  THE  STATE  FACILITY'S  COMPUTER  WOULD  BE 
INCLUDED  IN  THIS  SYSTEM.    THIS  WOULD  ALLOW  US  TO 
KNOW  THE  STATUS  OF  A  REACTOR,   i.e.  TEMPERATURE, 
PRESSURE,  WATER  LEVEL,  etc.  ON  A  REAL  TIME  BASIS, 
AS  WELL  AS  FURTHER  PROVIDE  EARLY  NOTIFICATION  OF 
EVENTS  THAT  COULD  LEAD  TO  NUCLEAR  ACCIDENTS. 

-  SECOND,  WE  ARE  RESPONSIBLE  FOR 
INVESTIGATING  DISEASE  OUTBREAKS  IN  THE 
COMMONWEALTH,   INCLUDING  THOSE  THAT  MAY  BE  CAUSED 
BY  CONTAMINATION  IN  THE  ENVIRONMENT.    WE  ARE 
CURRENTLY  CONDUCTING  A  STUDY  IN  THE  PLYMOUTH  AREA 
INTO  THE  CAUSES  OF  ELEVATED  RATES  OF  LEUKEMIA,  A 
TYPE  OF  CANCER  THAT  CAN  BE  CAUSED  BY  EXPOSURE  TO 
IONIZING  RADIATION. 


450 


-4- 
TEN  MONTHS  AGO,  THE  DEPARTMENT  CONCLUDED  AN 
ASSESSMENT  OF  ALL  HEALTH  RELATED  DATA  FOR  THE 
AREA  AROUND  THE  PLANT  IN  ORDER  TO  DETERMINE 
WHETHER  THE  HEALTH  OF  SOUTH  SHORE  RESIDENTS  MIGHT 
BE  AFFECTED  BY  THE  PILGRIM  REACTOR. 

THAT  ASSESSMENT  SHOWED  NO  UNUSUAL 
STATISTICAL  TRENDS  IN  THE  PATTERN  OF  CANCER 
DEATHS  OR  IN  THE  FREQUENCY  OF  INFANT  MORTALITY  OR 
LOW-BIRTHWEIGHT.   WHILE  SOME  ANOMALIES  IN  INFANT 
MORTALITY  AND  LOW  BIRTHWEIGHT  HAVE  BEEN  REPORTED, 
THE  NUMBERS  ARE  SO  SMALL  THAT  IT  IS  IMPOSSIBLE  TO 
DRAW  ANY  STATISTICALLY  VALID  CONCLUSIONS.   WE  DID 
FIND  A  STATISTICALLY  SIGNIFICANT  EXCESS  IN  THE 
INCIDENCE  OF  CANCERS  OF  THE  BLOOD-FORMING  ORGANS 
AMONG  MALES  IN  THE  FIVE  COASTAL  COMMUNITIES 
SURVEYED.   THESE  ELEVATIONS  ARE  AMONG  THE  TYPES 
OF  LEUKEMIA  THAT  CAN  BE  CAUSED  BY  EXPOSURE  TO 
RADIATION.   THE  INCIDENCE  OF  LEUKEMIA  AMONG 
FEMALES  WAS  ALSO  ELEVATED,  THOUGH  NOT  TO  THE  SAME 
SIGNIFICANT  DEGREE. 

THE  CRUCIAL  QUESTION,  OF  COURSE,  IS  WHETHER 
PILGRIM  IS  RESPONSIBLE  FOR  THE  HIGH  RATE  OF 
LEUKEMIA.   AT  PRESENT,  IT  IS  IMPOSSIBLE  TO  ANSWER 
THAT  QUESTION  UNEQUIVOCALLY,  BUT  THE  DEPARTMENT 
OF  PUBLIC  HEALTH  IS  CURRENTLY  CONDUCTING  TWO 


451 


-5- 
SEPARATE  INVESTIGATIONS  THAT  MAY  BRING  US  CLOSER 
TO  THE  ANSWER. 

FIRST,  WE  ARE  CONDUCTING  A  CASE-CONTROL 
EPIDEMIOLOGIC  STUDY  TO  HELP  US  IDENTIFY  THE 
POSSIBLE  CAUSES  OF  THE  EXCESS  LEUKEMIA. 

IN  THE  COURSE  OF  THIS  STUDY,  WE  WILL 
INTERVIEW  ALL  LEUKEMIA  CASES  DIAGNOSED  SINCE 
1982,  OR  THEIR  FAMILIES,  IN  THE  COMMUNITIES  OF 
PLYMOUTH,  KINGSTON,  DUXBURY,  MARSHFIELD  AND 
SCITUATE.   WE  WILL  TAKE  DATA  ON  THEIR  PLACES  OF 
RESIDENCE,  OCCUPATION,  AND  MEDICAL  HISTORIES. 
THIS  INFORMATION  WILL  BE  COMPARED  WITH  SIMILAR 
DATA  FROM  PEOPLE  WITHOUT  LEUKEMIA  FROM  THE  SAME 
COMMUNITIES  IN  ORDER  TO  LOOK  FOR  ANY 
DIFFERENCES.   THIS  STUDY  WILL  HELP  DETERMINE 
ASSOCIATIONS  BETWEEN  LEUKEMIA  AND  POSSIBLE 
SOURCES  OF  EXPOSURE  SUCH  AS  CHEMOTHERAPY  AND/OR 
RADIATION  THERAPY. 

WE  MUST  BE  VERY  FRANK  ABOUT  THE  LIMITATIONS 
OF  THIS  STUDY.    EPIDEMIOLOGY  HAS  ITS  LIMITS, 
ESPECIALLY  IN  CASES  SUCH  AS  THIS  WHEN  WE  ARE 
DEALING  WITH  SMALL  POPULATIONS,  RELATIVELY  SMALL 
NUMBERS  OF  CASES,  SMALL  DOSES,  AND  SMALL  LEVELS 


452 


-6- 
OF  EXPOSURE.    BUT  IF  WE  DON'T  LOOK,  WE  WON'T 
LEARN  ANYTHING  AT  ALL. 

SECOND,  WE  ARE  LOOKING  INTO  THE  POSSIBILITY 
THAT  COASTAL  WIND  PATTERNS  MAY  HAVE  CONTRIBUTED 
TO  THE  DISPERSION  OF  RADIATION  EMISSIONS  FROM 
PILGRIM  IN  A  WAY  THAT  BYPASSED  EXISTING  RADIATION 
MONITORING.    THIS  WORK,  BEING  CONDUCTED  THROUGH  A 
CONTRACT  WITH  THE  HARVARD  SCHOOL  OF  PUBLIC 
HEALTH,  WILL  DETERMINE  THE  FEASIBILITY  OF 
ESTIMATING  THE  LEVEL  OF  RADIATION  REACHING  THE 
GENERAL  POPULATION. 

IT  IS  OUR  OBJECTIVE  THAT  THE  COMBINED 
RESULTS  OF  THESE  INVESTIGATIONS  WILL  PERMIT  AN 
INFORMED  ESTIMATE  OF  THE  CONTRIBUTION  OF  PILGRIM 
EMISSIONS  TO  THE  ELEVATED  INCIDENCE  OF  LEUKEMIA 
IN  THE  VICINITY  OF  PILGRIM. 


453 

The  Chairman.  Thank  you  very  much,  Doctor.  We  appreciate 
your  testimony  and  your  comments. 

Let's  move  to  Ms.  Pollard.  I  know  that  we're  relying  to  some 
degree  on  HydroQuebec;  is  that  correct. 

Ms.  Pollard.  We  are  receiving — 3  percent  of  the  electricity  we 
use  in  New  England  is  imported  from  Canada,  so  right  now  it  is  a 
very  small  percentage.  It  increases  to  about  10  percent  by  the  year 
1991.  About  10  percent  of  all  the  electricity  that  we  use  is  not  con- 
sidered excessive.  However,  any  additional  import  of  electricity 
beyond  that  would  have  to  be  looked  at  that  for  that  reason,  we 
know  from  past  experience  that 

The  Chairman.  Someone  mentioned  to  me,  earlier  today,  about 
the  possibility  of  importing  energy  from  the  midwest. 

Ms.  Pollard.  Yes. 

The  Chairman.  I'm  unfamiliar  with  both  possibilities,  the  reali- 
ties and  the  difficulties. 

Ms.  Pollard.  Very  briefly,  the  governors  of  New  England  have 
spoken  with  some  of  the  Governors  in  the  Midwest  that  have  some 
coal  resources  within  their  States.  It  would  work  this  way.  That 
New  England  ratepayers  would  bill  powerplants  in  the  Midwest, 
that  New  England  ratepayers  would  put  on  those  powerplants  the 
best  available  control  technology  to  help  with  our  acid  rain  situa- 
tion. 

It  is  thought  that  that  energy  would  still  be  reasonable  in  terms 
of  the  cost  to  the  ratepayers.  So  there  is  some  thought  that  you  get 
double  win  from  this.  That  your  access  is  reasonable  energy  prices 
and  that  you  are  also  helping  with  the  acid  rain  situation.  There  is 
only  one  problem.  You  would  have  to  put  a  transmission  line 
through  the  State  of  Pennsylvania  and  through  the  State  of  New 
York,  and  there  is  some  concern  that  those  two  States  might  not  be 
thrilled  about  the  idea. 

The  Chairman.  Let's  keep  moving  on.  I'd  like  to  know  more 
about  it.  We'll  inquire.  You  are  probably  aware  of  the  Department 
of  Energy  comparing  the  record  of  powerplants  nationwide,  and  the 
Department  of  Energy  rated  New  England  23  out  of  26  in  its  abili- 
ty to  keep  its  plants  open  from  1983  to  1985.  I  wonder  if  you  are 
familiar  with  those  findings,  and  if  so 

Ms.  Pollard.  We  are. 

The  Chairman  [continuing].  What  you  concluded. 

Ms.  Pollard.  The  Federal  Department  of  Energy  has  conducted 
that  history.  We  are  obviously  not  pleased  with  the  evidence  and 
the  information  that  was  presented  in  that  report.  We  have  our 
powerplants  not  maintained  as  well  as  other  powerplants  in  other 
parts  of  the  country;  our  have  a  tendency  to  be  down  at  a  more 
frequent  rate  than  in  other  parts  of  the  country.  And  we  believe 
that  part  of  the  problem  this  past  summer  was  just  precisely  that. 
When  you  have  one-third  of  your  available  electricity  down  and 
unable  to  be  used,  that's  what  causes  you  some  concern  and  it  may 
cause  you  some  problem. 

We  have  continued — have  in  the  past,  and  will  continue  to  en- 
courage the  utilities  to  maintain  their  plants  well  and  to  schedule 
their  maintenance  at  times  of  the  year  when  we  are  not  experienc- 
ing the  greatest  demand  for  electric. 


454 

The  Chairman.  What  is  the  single  most  important  criterion  for 
judging  whether  or  not  the  Pilgrim  plant  should  be  operational? 

Ms.  Pollard.  The  health  and  safety  of  the  people  who  live 
within  the  radius  of  this  power  plant  and  that  is  the  most  impor- 
tant criteria  that  the  Governor  will  consider. 

The  Chairman.  Doctor,  let  me  ask  you  how  you  respond  to  some 
of  the  criticism  you  heard  earlier  levied  against  the  Department 
concerning  its  interaction  with  residents  of  the  local  area  as  well 
as  statewide?  We  know  you  just  recently  become  the  Commissioner 
with  responsibilities  concerning  these  difficulties  which  allegedly 
had  existed  earlier,  but  I  imagine  you  had  heard  of  them  and  were 
concerned  about  them,  and  I'm  just  wondering  what  kind  of  reas- 
surance you  might  be  able  to  give  people  in  the  area,  and  the  way 
you  might  perceive  situations? 

Dr.  Prothrow-Stith.  I  think  it's  important  to  say  that  we  are 
committed  to  the  health,  and  the  protection  of  the  health,  of  the 
citizens  of  the  Commonwealth,  and  as  a  new  commissioner  in  the 
Department  of  Public  Health,  that  commitment  is  something  that  I 
feel  very  comfortable  reaffirming. 

It  is  important  to  say  that  I  think  part  of  the  history  of  the  prob- 
lem that  we  have  had  has  been  a  situation  where  some  promises 
were  made  that  were  not  able  to  be  met  and  perhaps  mistakes 
were  made.  I  don't  know  the  details  of  those  histories,  but  I  would 
say  very  clearly  to  the  citizens  here  tonight  that  the  commitment 
is  strong  at  the  Department  of  Public  Health  and  we  intend  not 
only  to  complete  these  studies,  but  to  work  with  the  community,  as 
we  have  continued  to  do  in  the  last  few  months,  in  order  to  make 
sure  that  the  health  and  safety  concerns  are  addressed. 

The  Chairman.  Well,  I  think  from  what  I  have  known  of  you, 
the  people  in  this  area  would  have  a  good  sense  of  your  apprecia- 
tion for  those  concerns  and  your  commitment  because  I  know  it 
will  be  carried  forward. 

I  think  you  talked  about  our  request  for  a  study  by  the  NIH.  You 
might  be  helpful  to  us  who  are  working  with  the  NIH,  in  terms  of 
assistance  in  the  development  of  that  study.  I  would  ask  you  to  do 
that  at  some  time. 

Dr.  Prothrow-Stith.  What  I  would  like  to  do,  perhaps,  is  to  for- 
ward to  you  some  of  the  information  that — in  a  cover  letter,  that  I 
could  send  Dr.  Winegarten  offering  what  we  currently  know  in  our 
participation. 

The  Chairman.  A  final  point.  Boston  Edison  has  been  identified 
as  having  a  higher  rate  of  worker  exposure.  Does  the  Department 
of  Public  Health  have  the  option  of  conducting  a  study  of  worker 
exposure  or  is  this  something  that  is  referred  to  OSHA. 

Dr.  Prothrow-Stith.  The  Department  of  Labor  has  that  respon- 
sibility. Edison  and  the  Department  of  Labor  are  looking  into  that 
issue.  We  would  encourage  that  more  be  done.  It  is  important,  and 
I  think  the  NIH  participation  may  help  us  with  this,  to  look  at  na- 
tional data  and  some  international  data,  as  well  as  worker  data,  as 
a  way  to  fully  appreciate  the  health  risks.  So  I  would  encourage 
that  more  be  done,  and  if  we  can  help  in  any  way,  though  it  is  not 
our  direct  responsibility,  we  would  be  willing  to  do  that. 

The  Chairman.  I  want  to  thank  the  panel.  We  had  a  chance  to 
see  your  full  testimony  and  you  covered  many  additional  areas 


455 

which  we  were  interested  in.  I  think  this  panel  has  helped  us  to 
understand  better  the  problems  of  emergency  planning,  energy 
supplies,  and  the  public  health  concerns.  We  value  very  much  all 
of  your  testimony.  It  has  been  very,  very  helpful.  I  know  now 
where  to  go  for  additional  information,  so  we  are  grateful  to  all  of 
you. 

Dr.  Prothrow-Stith.  Senator,  may  I  say  one  other  thing.  I  just 
learned  that  the  utilities  pay  for  the  monitoring  system  in  Illinois. 

The  Chairman.  I  wonder  where  that  little  bit  of  information 
came  from.  [Laughter.] 

We  have  a  final  panel.  We  want  to  give  them  some  attention. 
We're  going  to  proceed  to  that  panel.  We  have  been  in  session  for 
three  hours.  I  want  you  to  know  this  is  a  very  important  panel.  We 
put  great  emphasis  on  it.  I  would  like  to  have  about  a  10-minute 
recess,  and  then  we're  going  to  stay  here  as  long  as  it  takes  to  run 
through  the  last  panel.  We  want  to  give  them  our  attention.  We 
have  important  questions,  but  we  want  to  take  our  time  with  that 
panel.  They  deserve  attention. 

You  have  been  a  very  attentive  audience.  This  has  been  a  very 
informative  hearing.  We  have  collected  a  great  deal  of  information 
and  we're  grateful  to  all  of  those  who  participated  and  helped  us, 
but  since  we  have  been  in  here  for  this  period  of  time,  we  will  have 
a  10-minute  recess.  I  know  some  people  have  to  leave.  We're  grate- 
ful to  them  for  their  presence,  but  I  would  hope  as  many  as  possi- 
ble would  stay.  I  think  this  will  be  an  informative  session  with  the 
laist  panel. 

[Ten-minute  recess.] 

The  Chairman.  I  ask  that  everybody  rejoin  us  and  take  their 
seats  so  we  can  give  our  full  attention  to  the  final  panel.  Again, 
you've  very  attentive.  We'll  ask  that  people  be  kind  enough  to  take 
their  seats. 

First  of  all,  we  want  to  thank  Nadine  O'Neill,  and  I'm  going  to 
ask  all  of  you  if  you  will  join  in  giving  our  wonderful  interpreter  a 
hand  this  evening. 

[Applause.] 

The  Chairman.  She's  doing  a  magnificent  job. 

I  shall  ask  our  panelists  if  they  will  be  kind  enough  to  raise  their 
hands  and  do  say  if 

[Witnesses  sworn.] 

The  Chairman.  We  have  a  few  housekeeping  details,  we  have 
statements  from  some  of  our  colleagues.  Representative  Studds, 
and  Senator  Kerry,  and  we  will  include  their  statements  in  the 
record.  I'll  indicate  to  those  whose  testimony  we  have  not  been  able 
to  receive  in  person,  given  the  time  that's  been  available  to  us, 
we'll  be  glad  to  receive  that